G.R. No. 212611 - Heirs of Batori vs. Register of Deeds of Benguet

A petition for review on certiorari under Rule 45 of the Rules of Court was filed by the heirs of Batori, represented by Gladys B. Abad, seeking to reverse and set aside the Court of Appeals’ resolutions dated November 19, 2013, and May 20, 2014.
The underlying controversy stemmed from a complaint filed for the annulment and/or cancellation of an Original Certificate of Title (OCT) issued to Pacita Galvez as a result of her Free Patent application.

The late Batori had possessed a 6,000-square meter parcel of land in La Trinidad, Benguet since time immemorial, which was registered under Tax Declaration No. 1032 in 1945.
In October 1948, the land was surveyed and identified as Lot 1, as evidenced in PSU No. 121133.
In April 1956, Batori applied for a Free Patent and the issuance of a title from the Bureau of Lands; he occupied the land until his death.
Batori’s heirs, including Abad, subsequently continued the possession of the land.

In February 2000, Abad, while following up on Batori’s Free Patent application at the Department of Environment and Natural Resources (DENR), discovered an amended survey approved on August 30, 2000.
The amended survey of PSU No. 121133 subdivided Lot 1 into three distinct lots:

Abad questioned the legitimacy of Galvez’s inclusion as an owner since Galvez was neither one of Batori’s heirs nor had any waiver been executed in favor of Galvez.

An additional amended survey on PSU No. 1000175, registered in the name of Johnson Andres, indicated that 2,000 square meters of Andres’ property allegedly overlapped with Batori’s property under PSU No. 121133.
Abad filed a protest with the DENR-Cordillera Administrative Region (CAR) for the annulment of PSU No. 1000175.
Although the DENR-CAR initially ruled in Abad’s favor, the Secretary of the DENR ultimately upheld the validity of both survey plans and ordered the segregation of Lot 1, prompting Abad to appeal the decision before the Office of the President (OP).

In April 2008, Abad was surprised to learn that Galvez had secured OCT No. 21449, issued on May 28, 2007, based on a Free Patent application supported by PSU No. 1000175 from the Provincial Environment and Natural Resources Office (PENRO).
Believing that the title was obtained fraudulently, Abad filed her complaint before the Regional Trial Court (RTC).
Galvez, in her answer, contended that her Free Patent application was based solely on PSU No. 1000175, not the disputed PSU No. 121133, and asserted that the overlapping issues had already been settled by the DENR.

The parcel of land involved in Galvez’s Free Patent application was part of the land subject to Batori’s original application.
Evidence negated Galvez’s contention that her application involved a different piece of land, thereby implicating her in fraudulent conduct.
Since Galvez was not among Batori’s heirs, her right to inherit was invalid despite the amended survey’s subdivision.

Consequently, the RTC declared OCT No. P-21449 null and void and ordered its cancellation.
Galvez subsequently filed a motion for reconsideration. On April 1, 2011, the RTC reversed its November 18, 2010 decision, holding that:

Fraud must involve deliberate and intentional conduct—a standard not met by Galvez, as her application was based on a final DENR decision.
The principle of res judicata bound the parties, thus favoring the finality of the DENR decision and dismissing the fraud allegations.

In its November 19, 2013 resolution, the CA dismissed Abad’s appeal for her failure to comply with its order to furnish proof of receipt of her appellant’s brief by Galvez’s counsel.
The CA reiterated that Galvez’s Free Patent application was grounded on a final and executory decision by the DENR, thereby dismissing the fraud claims.
Following a subsequent motion for reconsideration by Abad, the CA, in its May 20, 2014 resolution, denied the motion due to non-compliance with its directives and maintained its dismissal on the merits of the case.
Abad’s subsequent arguments stressed that the CA improperly prioritized procedural technicalities over the substantive merits of her case and that the CA’s resolutions did not comply with constitutional and legal guidelines regarding the form and substance of judicial decisions.

Whether the Court of Appeals (CA) committed reversible error by giving more weight to procedural technicalities—specifically, Abad’s delayed compliance in furnishing proof of receipt of her appellant’s brief—than to the merits of the case.
Whether the CA issued resolutions that are constitutionally infirm for not conforming to the form and substance requirements mandated by the Constitution and the Rules of Court.