G.R. No. 71905 - Midland Insurance Corp. vs. Intermediate Appellate Court

On December 19, 1995, Ma. Lourdes A. Teodoro (respondent) filed an application for the registration of two parcels of land located at Barangay San Pedro, Virac, Catanduanes.
The subject lots, identified as Lot Nos. 525-A and 525-B (Csd.-05-010483-D of the Virac Cadastre), have an aggregate area of 284 square meters.
Respondent claimed that, except for the commercial building erected on the property, she acquired the lots from her father, Pacifico Arcilla, as evidenced by a Deed of Sale dated December 9, 1966.
It was further alleged that Pacifico Arcilla had itself obtained the lots through a partition of the estate of his father, Jose Arcilla, as shown by an Extrajudicial Settlement of Estate.
In support of her claim, respondent also introduced an Affidavit of Quit-Claim executed in favor of Pacifico by the petitioners, who are the heirs of Vicente Arcilla (brother of Pacifico).

Petitioners, namely Aida Arcilla Alandan, Rene A. Arcilla, Oscar A. Arcilla, Sarah A. Arcilla, and the late Nora A. Arcilla (substituted by her son Sharmy Arcilla), contended that they are the true and absolute owners pro-indiviso of the subject lots.
They asserted that the disputed lots, including the commercial building and other improvements, were inherited from their deceased parents, Vicente and Josefa Arcilla.
Petitioners maintained that their father, Vicente Arcilla, had purchased the lots from Manuel Sarmiento as early as 1917, a fact purportedly evidenced by several tax declarations, and that they had been in possession of the property since 1906.

The case was initially filed in the Regional Trial Court (RTC) of Virac, Catanduanes and later transferred on February 7, 1996, to the Municipal Trial Court (MTC) in Virac due to an expansion of jurisdiction under Republic Act No. 7691.
During the proceedings, respondent sought to admit a belated filing of a sworn certification against forum shopping, contending that the initial omission was due to oversight and inadvertence.
Petitioners moved to dismiss respondent’s application on the ground that the certification against forum shopping should have been filed simultaneously with the petition for registration, as required by SC Administrative Circular No. 04-94.
On July 19, 1999, the MTC denied petitioners’ motion to dismiss. Subsequently, on June 25, 2001, the MTC rendered a decision confirming and registering the land in the name of respondent.
Petitioners appealed the decision; however, the RTC in its February 22, 2002 decision dismissed their appeal for lack of merit and later denied their Motion for Reconsideration.
Petitioners then elevated the matter to the Court of Appeals (CA) by filing a Petition for Review. On September 12, 2003, the CA dismissed the petition and later denied a Motion for Reconsideration on March 24, 2004.
Aside from contesting the belated filing of the certification of non-forum shopping, petitioners questioned:

The substantial compliance with SC Administrative Circular No. 04-94 despite the delay.
The requirement for a certification from an officer of the foreign service per Section 24, Rule 132 of the Rules of Court regarding a notarized foreign document.
The proper ownership of the subject lots by their father, Vicente Arcilla, challenging the evidentiary basis of respondent’s claim.

Petitioners also raised the broader issue of whether the Supreme Court may reexamine conclusions of fact rendered by the lower courts and the CA.

Whether the belated filing (after more than two years and three months) of the sworn certification against forum shopping in respondent’s application constitutes substantial compliance with SC Administrative Circular No. 04-94 and Section 5, Rule 7 of the Rules of Court.
Whether the certification of non-forum shopping, when notarized in a foreign country, requires an accompanying certification from an officer of the foreign service as mandated by Section 24, Rule 132 of the Rules of Court.
Whether the lower courts erred in determining that the subject lots were not owned by petitioners’ father, Vicente Arcilla, notwithstanding the evidence of tax declarations and possession presented by petitioners.
Whether the evidentiary value of notarized documents (i.e., the Deed of Sale, Extrajudicial Settlement of Estate, and the Affidavit of Quit-Claim) is sufficient to establish respondent’s ownership over the disputed property against petitioners’ contentions.
Whether the Supreme Court may inquire into and reverse the factual findings of the lower courts in this case.