G.R. No. 199777 - Heirs of Kuli vs. Pia

The case involves a Petition for Review filed by the heirs of Datu Dalandag Kuli (petitioners) against Daniel R. Pia, Filomena Follosco, and Jose Follosco, Sr. (respondents).
The dispute centers on Lot 2327, which was originally awarded to Datu Kuli through cadastral proceedings and registered by the Register of Deeds of Cotobato City on 12 November 1935 as evidenced by Original Certificate of Title (OCT) No. 1654.

After Datu Kuli’s death on 8 July 1985, the possession of Lot 2327 passed to his heirs, who continued to hold the property.
When the petitioners sought to have Datu Kuli’s title reconstituted, they were informed that a different title had already been issued in the name of Jose Follosco, Sr.
Records indicate that:

On 21 December 1940, a Transfer Certificate of Title (TCT) No. 1608 covering Lot 2327 was issued in respondent Pia’s name on the basis of a presented deed purportedly executed by Datu Kuli.
The Register of Deeds, although unable to produce the actual copy of the Deed of Sale due to its deteriorated condition, issued a certification that such a deed was presented.
Later administrative entries led to further changes: on 14 July 1948, TCT 1608 was administratively reconstituted using a duplicate, and following another conveyance, a new title (TCT T-374) was issued in the name of respondent Filomena Follosco, which was eventually cancelled and replaced by TCT T-2911 in the name of respondent Jose Follosco, Sr.

Petitioners filed a Complaint for Quieting of Title with the Regional Trial Court (RTC), praying for the restoration of OCT No. 1654 and the annulment of the subsequent titles issued in the names of the respondents.
Due to difficulties in service, the RTC eventually ordered service by publication, and respondents were declared in default by order of the RTC.
On 16 January 2004, the RTC rendered its Judgment in favor of the respondents, holding that the petitioners failed to overcome the presumption of regularity in the issuance of TCT 1608.
The Court of Appeals (CA) affirmed the RTC’s decision on 28 January 2011 and subsequently issued a Resolution on 6 December 2011.
Petitioners then filed a Petition for Review on Certiorari, which eventually was denied by the Supreme Court.

The Register of Deeds relied on evidence from its Primary Entry Book, which noted the registration details of the Deed of Sale executed by Datu Dalandag Kuli in favor of Daniel R. Pia on 21 December 1940, despite the physical deed no longer being legible or available.
The procedures followed in the issuance and subsequent reconstitution of TCT 1608 conformed with the guidelines in Section 57 of the Property Registration Decree and Republic Act No. 26, which governs the reconstitution of lost or destroyed titles.

Did the Register of Deeds properly issue TCT 1608 in the name of Daniel R. Pia despite the absence of a legible copy of the Deed of Sale?
Can the certification from the Register of Deeds’ entry be accepted as sufficient evidence of the conveyance?

Did the petitioners establish a legal or equitable interest in Lot 2327 by virtue of their continued possession?
Were the petitioners able to demonstrate that the underlying cause of action—the alleged invalid conveyance—was legally or factually insufficient, particularly in light of the presumption of regularity in the issuance of land titles?

Was the administrative reconstitution of TCT 1608, as carried out by the Register of Deeds under Republic Act No. 26, correctly performed and valid?