G.R. No. 141443 - IN RE: Azucena L. Garcia

On October 27, 1989, Azucena L. Garcia filed an application for land registration with the RTC of Quezon City (Branch 80) covering two parcels of land (Lots Nos. 822-C-1 and 822-C-2) having areas of 32,350 sq. m. and 28,750 sq. m., respectively.
The application was supported by documents including two tax declarations (Nos. 2273 and 22732), a subdivision plan (Psd-19954), and technical descriptions of each lot.
There is no record of substantive proceedings on the original registration application, and subsequent events indicate that the application was eventually abandoned.

On May 8, 1991, Garcia submitted an application for the administrative reconstitution of Transfer Certificate of Title (TCT) No. 308462 with the Land Registration Authority.
Along with reproductions of the earlier documents, the application included the owner’s copy of TCT No. 308462 and assorted real property tax receipts.
On June 7, 1991, a certification was issued by Edgardo Castro, Deputy Register of Deeds, that the original TCT was among those burned in the 1988 fire at Quezon City Hall.
On June 20, 1991, pursuant to Administrative Order No. Q-283(91), the reconstitution of TCT No. 308462 was ordered.

On September 10, 1991, complainant Antonio de Zuzuarregui sent a request to the Quezon City Assessor’s Office to verify the authenticity of the declarations of real property attached to Garcia’s application.
The Assessor’s Office, in a reply dated September 11, 1991, indicated that no such records existed and suggested the declarations were spurious.
Subsequent correspondence, including letters to the Bureau of Lands, further questioned the authenticity of:

On September 23, 1991, Garcia, represented by counsel, filed a motion to withdraw her land registration application, which was granted shortly thereafter.

On November 11, 1991, Zuzuarregui instituted a criminal complaint against Garcia charging falsification of public documents.
This complaint related to the alleged falsification of technical descriptions, tax declarations, and other documents supporting the reconstitution of TCT No. 308462.
The criminal case was docketed as Criminal Cases Nos. Q-94-53589, Q-94-53590, and Q-94-53591.
Various evidentiary proceedings ensued, including:

Findings by the National Bureau of Investigation concerning the questioned signatures on the TCT.
Certifications by city assessors indicating that the tax declarations and technical documents did not appear in official records.
Interoffice memoranda and requests for verification from officials of the Bureau of Lands.

A Supplemental Order dated October 8, 1991, set aside the previous reconstitution order regarding TCT No. 308462.
Garcia appealed the Supplemental Order to the LRA Administrator.

On September 30, 1994, the LRA Administrator issued a Resolution affirming the finality of the August 20, 1991 reconstitution order.
The resolution clarified that the reconstitution did not adjudicate ownership over the property, but merely reconstituted the title.

Garcia was charged in Criminal Case No. Q-94-53589 with falsifying entries in TCT No. 308462 and in Criminal Cases Nos. Q-94-53590 and Q-94-53591 for falsifying the declarations of real property.
On April 20, 1995, the trial court found Garcia guilty on all counts. The Court of Appeals and subsequently the Supreme Court affirmed the conviction.
Entry of Judgment was recorded on April 8, 1999.
In her petition for habeas corpus, Garcia contended that:

Her constitutional rights to due process were violated by the trial court’s failure to introduce or properly consider evidence establishing the genuineness of the signature of Vicente Coloyan.
There was prosecutorial misconduct by failing to exclude a possibly corrupt and perjured witness.
She was denied effective counsel, particularly regarding the presentation of exculpatory evidence.

Habeas corpus is a remedy for illegal detention only, and since Garcia was out on bail, the petition was inapplicable.
The petition sought to reexamine evidentiary determinations properly within the trial court’s discretion instead of being a proper ground for a writ.

Whether the writ of habeas corpus is available to a person who is out on bail and has been convicted by final judgment.
Whether the alleged violations of due process by the trial court (failure to introduce certain evidence concerning the authenticity of Coloyan’s signature) can constitute grounds for a habeas corpus petition.

Whether the official acts and determinations (including administrative reconstitution orders and certifications regarding document authenticity) were properly given weight in the trial court’s appreciation of the evidence.
Whether the failure to formally adduce evidence related to the genuineness of Coloyan’s signature amounts to a manifest error that deprived Garcia of her right to due process.
Whether prosecutorial misconduct (such as presenting a potentially corrupt witness) and ineffective assistance of counsel can be remedied by habeas corpus.

Whether issues involving appreciation of evidence and conflicts concerning document authenticity fall within the proper scope of review in habeas corpus proceedings.
The implications of the final and executory nature of the judgment on the availment of extraordinary relief.