G.R. No. 212598 - Gaw Chin Ty vs. Chua

Spouses Gaw Chin Ty and Chua Giok See purchased a parcel of land covered by Transfer Certificate of Title (TCT) No. 420866.
By custom, the spouses registered the property in the name of their first-born son, respondent Antonio Gaw Chua (Antonio).
To protect the rights of other children, the spouses entrusted the original owner’s duplicate copy of TCT No. 420866 to their second eldest son, petitioner Vicente Gaw Chua.

Antonio claimed loss of the original owner’s duplicate copy of TCT No. 420866 and filed a verified petition for issuance of a new/reconstituted duplicate with the Regional Trial Court (RTC).
On August 15, 2000, the RTC declared the original owner’s duplicate as null and void and ordered issuance of a new owner’s duplicate copy to Antonio.
The Registry of Deeds (RD) of Malabon City issued the new owner’s duplicate copy pursuant to the RTC decision.

On August 27, 2001, Gaw Chin Ty and her children filed a Notice of Adverse Claim over TCT No. 420866, inscribed by the RD on August 31, 2001.
Antonio filed a physical injury complaint against Vicente before the barangay; attempts at conciliation involved matters relating to the subject property but failed.
On June 24, 2009, Antonio filed a petition for cancellation of the adverse claim before the RTC; mediation failed, case set for pre-trial.
Antonio also filed a criminal complaint for slight physical injury against Vicente at the Metropolitan Trial Court (MeTC).

On September 23, 2009, petitioners filed a petition to annul the new/reconstituted owner’s duplicate copy of TCT No. 420866 with the RTC.
Petitioners alleged that the original owner’s duplicate was not lost, but in their possession, and that Antonio knew this fact.
They also claimed the title was held in trust for the family under Filipino-Chinese customary practice.
At pre-trial, Vicente presented the original owner’s duplicate copy which Antonio acknowledged but claimed was fake.
The RTC allowed Antonio to rebut the presumption of regularity of the original duplicate, but he failed to prove it was spurious after several trial dates.
On June 14, 2012, the RTC granted the petition to annul the new owner’s duplicate title and declared it null and void. Antonio’s motion for reconsideration was denied.

Antonio appealed to the CA, which reversed the RTC’s decision on September 27, 2013, dismissing the petition for failure to comply with a condition precedent under Article 151 of the Family Code.
Petitioners’ motion for reconsideration before the CA was denied on May 12, 2014.
Petitioners filed a Petition for Review on Certiorari with the Supreme Court assailing the CA decisions.

Whether the petition to annul the new owner’s duplicate copy of TCT No. 420866 should be dismissed for failure to allege compliance with, or failure to comply with, the condition precedent for filing the petition under Article 151 of the Family Code.

Whether the issue of a new owner’s duplicate title co-existing with a valid and existing original owner’s duplicate title can be the subject of compromise among family members.