Case Digest (G.R. No. 162886)
Facts:
Heirs of the Deceased Spouses Vicente S. Arcilla and Josefa Asuncion Arcilla, namely: Aida Arcilla Alandan, Rene A. Arcilla, Present: Oscar A. Arcilla, Sarah A. Arcilla, and Nora A. Arcilla, now deceased and substituted by her son Sharmy Arcilla, Chairperson, represented by their attorney-in-fact, Sarah A. Arcilla v. Ma. Lourdes A. Teodoro, G.R. No. 162886, August 11, 2008, Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.On December 19, 1995, Ma. Lourdes A. Teodoro filed with the Regional Trial Court (RTC) of Virac, Catanduanes an application for registration of two parcels (Lot Nos. 525‑A and 525‑B, aggregate 284 sq. m.) located in Barangay San Pedro, Virac. She claimed to have purchased the lots from her father, Pacifico Arcilla, by a Deed of Sale dated December 9, 1966, and relied further on an Extrajudicial Settlement of Estate (purportedly of Jose Arcilla) and an Affidavit of Quitclaim executed in favor of Pacifico by petitioners as heirs of Vicente Arcilla.
Because of jurisdictional changes under Republic Act No. 7691, the case was transferred on February 7, 1996 to the Municipal Trial Court (MTC) of Virac. Petitioners opposed, asserting ownership pro‑indiviso by inheritance from their parents Vicente and Josefa Arcilla, claiming Vicente bought the lots from Manuel Sarmiento c.1917 and producing tax declarations and long possession as evidence. Petitioners moved to dismiss on the ground that respondent failed to file the certification against forum shopping required under Supreme Court administrative circulars and the Rules of Court.
Trial ensued. On March 20, 1998 respondent filed a Motion for Admission, explaining she inadvertently omitted the required verification and certificate against forum shopping. Petitioners filed a Motion to Dismiss the application. On July 19, 1999 the MTC denied petitioners’ Motion to Dismiss, and on June 25, 2001 the MTC rendered a decision awarding registration to respondent.
Petitioners appealed to the RTC, Branch 43, which on February 22, 2002 dismissed the appeal and affirmed the MTC decision; the RTC denied reconsideration on July 22, 2002. Petitioners then filed a Petition for Review with the Court of Appeals (CA). On September 12, 2003 the CA promulgated a decision dismissing petitioners’ petition and affirming the lower courts; its denial of petitioners’ motion for reconsideration was embodied in a Resolution dated March 24, 2004.
Thereafter petitioners filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court, raising: (a) that the CA erred in accepting respondent’s belated filing of the certification against forum shopping as substantial compliance with SC Administrative Circular No. 04‑94 and Section 5, Rule 7 of the Rules of Court; (b) that the certification notarized abroad requir...(Pro-only)
Issues:
- May the Supreme Court review the Court of Appeals’ factual findings in this case?
- Did respondent’s belated filing (over two years later) of the certification against forum shopping constitute substantial compliance with Section 5, Rule 7, Rules of Court and applicable Supreme Court circulars?
- Must a notarized certification of non‑forum shopping executed abroad be authenticated by an officer in the Philippine foreign service under Section 24, Rule 132, Rules of Court to be admissible?
- Was there sufficient evidence to overturn the lower courts’ factual findings th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)