G.R. No. 66344 - Lanzona vs. Intermediate Appellate Court

This petition for review arises from a decision of the Intermediate Appellate Court dated June 16, 1982, in CA-G.R. No. 52469-R, which reversed the order of the Court of First Instance of Davao (now Regional Trial Court) rendered on August 26, 1972.
The case involves petitioners Miguel Lanzona (deceased) and Iluminada E. Lanzona, and respondent Emilio Alvarez, successor-in-interest to Constancio Guzman.

On October 1, 1940, Judge Enrique Fernandez of the Court of First Instance of Davao delivered a decision adjudicating Lot No. 384 in favor of Constancio Guzman.
In that decision, reference was made to an earlier Supreme Court decision and evidentiary exhibits detailing claims to interests in the lot, including ownership of various improvements and crops.
Constancio Bolcan, whose interests were also mentioned, had appealed Judge Fernandez’s decision to the Court of Appeals; however, all records of this case were destroyed during the war and were never reconstituted.

On December 15, 1967, a decree of registration and Original Certificate of Title (O.C.T.) No. Q-217 were issued by the Land Registration Commission and the Register of Deeds for Davao City in favor of Guzman.
The petitioners alleged that they had acquired rights over the land and its improvements from Constancio Bolcan since 1942 and that they possessed the land for more than twenty-five years as exclusive owners.
They filed a petition for review of the decree of registration alleging fraud in its issuance.

Petitioners accused the issuance of the title of being fraudulent, relying on the fact that certain evidentiary aspects (such as a Supreme Court decision not certified as “true and correct”) could undermine the title’s validity.
Private respondent Emilio Alvarez argued that the decision of October 1, 1940, rendered by Judge Fernandez had become final and executory, thereby validating the title issued to Guzman.

The trial court initially ruled in favor of the petitioners by annulling the decree and ordering the issuance of a new title in their names.
The Intermediate Appellate Court reversed the trial court’s decision on June 10, 1982, dismissing the petition for review due to lack of merit, affirming the validity of Decree No. N-118060 and O.C.T. Q-217 in Guzman’s name.
A key issue arose from the pre-war decision’s finality and the failure to reconstitute the appeal due to the destruction of records during the war—an action interpreted as abandonment of the appeal by the petitioner’s predecessor-in-interest.

The petition for review was subsequently filed with the Supreme Court by Lanzona.
The core questions pertained to whether the Court of Appeals erred in its findings of no fraud and in treating the 1940 decision as final, despite the absence of reconstituted records.

Whether the Court of Appeals erred in holding that there was no fraud in the issuance of the decree of registration for Lot No. 384 and O.C.T. No. Q-217 in favor of Constancio Guzman.

Does the alleged absence of certified evidence (i.e., the non-certified decision of the Supreme Court relied upon by the trial court) constitute fraud under Section 38 of Act 496?
Was it erroneous to dismiss the petition for review on the ground that the pre-war decision by Judge Fernandez had become final and did not warrant reconstitution?

Whether the petitioners’ claim of ownership based on acquisitive prescription and continuous, undisturbed possession is factually and legally sustainable.

Does the evidence sufficiently demonstrate that the parcel of land acquired from Constancio Bolcan is the same as Lot No. 384 covered by O.C.T. Q-217?
Should the factual findings of the lower courts be reweighed or re-analyzed by the Supreme Court?