G.R. No. 149122 - Heirs of Venturanza vs. Republic

The case originated when the Republic of the Philippines, represented by the Office of the Solicitor General (OSG), filed a complaint for cancellation of Transfer Certificate of Title (TCT) No. 2574 and for the reversion of the land in question to the public domain.
The complaint was originally docketed as Civil Case No. IR-122 in the Regional Trial Court (RTC) of Iriga City, Branch 37, and later affirmed by the Court of Appeals (CA) in its decision dated January 31, 2001 (CA-G.R. CV No. 38630).
Petitioners, heirs of Gregorio and Mary Venturanza, sought to reverse the CA’s decision via a petition for review under Rule 45, challenging the cancellation and reversion order.

TCT No. 2574 was issued in 1959 in the name of Gregorio Venturanza, the then-owner who had acquired the land from Florencio Mora.
The title in question derived from TCT No. RT-40 (140), a reconstituted title issued to Florencio Mora, which itself was reconstituted from TCT No. 140.
TCT No. 140 was originally issued in connection with Land Registration Case (LRC) No. 3480, which pertained to a parcel of land originally registered in 1911 covering only 451 square meters, in sharp contrast to the vast area (23,944,635 square meters or 2,394 hectares) that was alleged in the subsequent titles.

Discrepancies were noted in the memorandum of registration for TCT No. 2574, with certain registration data missing (noted as “NA”), casting doubts on the authenticity of the title’s derivation.
During the negotiation for a sale arranged between Gregorio Venturanza and the Abaca Development Board in 1964, a government-appointed deputy clerk of the Land Registration Commission (LRC) verified the true copies of TCT No. 2574.
The verification revealed that while the title allegedly covered a vast tract in Buhi, Camarines Sur, its origin, through TCT No. RT-40 (140) and eventually TCT No. 140, actual correspondence in records indicated that the land was originally only 451 square meters—highlighting a significant anomaly.
Further incongruities were found in the resurvey plan and other records, which erroneously depicted the location and area, such as the association with timberland and conflicting details in the official maps and GRLO records.

On April 8, 1992, the RTC ordered the annulment and cancellation of TCT No. 2574 and mandated the reversion of the land to the public domain, basing its decision chiefly on the finding that the reconstituted title issued in the name of Florencio Mora may have been fraudulently secured, thereby being legally defective.
The petitioners (the heirs of the Venturanza couple), on appeal before the CA, argued that Mora’s reconstituted title should be considered indefeasible because it had attained finality one year after the reconstitution decision under Section 112 of Act No. 496.
Additionally, petitioners maintained that as buyers in good faith, they were entitled to protection under the law and contended that the earlier CA decision in a related case (CA-G.R. No. 20681-R) should bar the cancellation action by the State.
Notwithstanding these arguments, the CA and eventually the Supreme Court found that such reliance was misplaced, given the inherent irregularities and the inalienable nature of the timberland involved.

Whether the reconstituted title (TCT No. RT-40 (140)), from which TCT No. 2574 was derived, is legally valid and indefeasible despite its alleged irregularities.
Whether finality under the Land Registration Act applies to a reconstituted title that originated from defective or incomplete registration procedures.

Whether the petitioners’ defense as buyers in good faith could shield them from the cancellation of TCT No. 2574 despite the underlying irregularities in the title’s chain of registration.

Whether the lower courts, in ordering the cancellation of TCT No. 2574, had jurisdiction over a title derived from a land registration process that never properly incorporated the property within the ambit of the Land Registration Act.
Whether the decision rendered in CA-G.R. No. 20681-R, concerning a reconstitution process, possesses res judicata effect over the present cancellation action.

Whether the property, by virtue of being part timberland and within the public domain, could have ever been validly registered and subsequently conveyed under the prevailing legal standards, including the protections afforded by the Constitution.