Case Digest (G.R. No. 198968)
Facts:
In Heirs of Dionisio Deloy and Praxedes Martonito Deloy v. Verna R. Basa-Joaquin et al. (G.R. No. 241841, November 28, 2022), siblings Dionisio and Isabel Deloy owned Lot No. 4012 in Trece Martires City, Cavite, under TCT No. T-13784. Dionisio occupied five hectares and Isabel one hectare. After a 1959 fire destroyed the original title, the Register of Deeds reconstituted it as TCT No. (T-13784) RT 12612, allocating shares to Isabel, the Paredes spouses, Tomasa Figueroa, the Province of Cavite, and the Deloy spouses. Subsequent subdivision in 1966 created Lots 4012-A to 4012-M and new titles (T-19127 to T-19315). Dionisio died in 1985; Praxedes and their heirs discovered in 1989 that the Province held titles to Lots 4012-A and 4012-B. They filed an annulment case, and in 1998 the RTC declared TCT Nos. T-19127 and T-19128 and related deeds null and void. The CA affirmed in 2001, ordering cancellation of the reconstituted title and directing reissuance of a “new one in its originaCase Digest (G.R. No. 198968)
Facts:
- Antecedents
- Dionisio and Isabel Deloy were registered owners of Lot No. 4012 (6 ha.) under TCT No. T-13784; Court-approved subdivision (1966) created 13 lots (4012-A to 4012-M).
- Original TCT lost in 1959 fire; reconstituted as TCT (RT-12612) listing Isabel, Spouses Paredes, Tomasa, Province of Cavite, and Spouses Deloy.
- RT-12612 canceled; new TCTs issued: Province (Lots A, B), Tomasa (C), Spouses Paredes (G), Isabel (I), Dionisio (D, E, F, H, J, K, L, M). Dionisio died in 1985.
- Annulment Case (Civil Case No. TM-695)
- 1989: Praxedes Deloy and heirs sued Province and RD for annulment of RT-12612 and TCTs T-19127, T-19128.
- 1998 RTC Decision: deeds and TCTs T-19127, T-19128 null; ordered cancellation and issuance of new titles to heirs.
- 2001 CA Decision: affirmed annulment, directed cancellation of RT-12612 and reissue original with annotations upon payment of fees.
- RD complied: canceled RT-12612, issued T-66696; all Province-issued TCTs canceled.
- Subsequent Proceedings and Special Petitions
- Respondents (Verna R. Basa-Joaquin; Heirs of Spouses Del Rosario; Heirs of Maxima Guevarra) held TCTs for Lots J, K, L; RD demanded surrender for annotation of adverse claim by Heirs Deloy.
- Heirs Deloy posted notice of adverse claim; RD canceled respondents’ TCTs and issued new titles in Dionisio’s name; later issued TCT 82597 to Heirs Deloy after estate settlement.
- Respondents filed special proceedings (TMSCA-005-08; TMSCA-0008-07) to quiet title/remove cloud; Heirs Deloy appeared and argued SPA defect and effect of annulment.
- RTC (2012): declared Heirs Deloy in default; granted respondents’ petitions—validated respondents’ TCTs, canceled TCT 82597, deleted annotations, canceled tax declarations, awarded attorney’s fees.
- CA (2018): affirmed RTC—held substantial compliance on certification contra forum shopping; new trial denial proper; respondents proved good-faith titles.
- Heirs Deloy filed Rule 45 petition before the Supreme Court.
Issues:
- Did respondents substantially comply with the certificate against forum shopping requirement?
- Did the CA err in upholding the RTC’s denial of Heirs Deloy’s motion for new trial?
- Did the CA err in affirming the RTC’s grant of respondents’ petitions to quiet title?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)