G.R. No. 102961-62 - Liao vs. Court of Appeals

Jesus P. Liao, as petitioner, sought to annul the decisions of the Court of Appeals which had annulled an order of the Regional Trial Court (“RTC”) directing the issuance of transfer titles to Estrella Mapa over certain lots in the Piedad Estate, Quezon City.
The petition consolidated several cases involving conflicting issuance of Torrens titles over the same property.

On March 5, 1986, Estrella Mapa filed a petition with RTC Branch 99 for the reconstitution of documents and issuance of certificates of title over parcels of land covered by OCT 614 and Decree No. 6667, claiming that on June 16, 1913, the Director of Lands issued certificates of sale to Vicente Salgado under Act No. 1120 (Friar Lands Act).
The subject property consisted of four parcels (Lot Nos. 755, 777, 778, and 783) within the Piedad Estate, with areas varying between approximately 3.691 hectares and 25 hectares.
Vicente Salgado assigned the property to Estrella Mapa on April 12, 1930, which later became the basis of title issuance applications.

On June 30, 1986, after hearings, the RTC issued an order authorizing the Register of Deeds of Quezon City to reconstitute and issue a transfer title in the name of Estrella Mapa for Lot No. 778 and a portion of Lot No. 777.
Pursuant to this order, the Register of Deeds initially issued T.C.T. No. 348156 on August 5, 1986, and then, on August 12, 1986, cancelled it to issue T.C.T. Nos. 348291 and 348292 covering Lot No. 778 and a portion of Lot No. 777 respectively.
Several existing certificates of title covering the same property and a subsequent investigation by the National Bureau of Investigation gave rise to multiple actions for quieting title.

I.C. Cruz Construction, Inc. (ICC) filed a petition on March 28, 1990 before the Court of Appeals to annul the RTC order, alleging that the title issued under the order encompassed property already registered in its name under a different title (TCT No. 836975).
Arle Realty Development Corporation similarly filed a petition on July 3, 1990, claiming ownership of six lots covered by other titles which overlapped with the subject title (TCT No. 348292).
The cases were consolidated and set for a preliminary conference on March 21, 1991, during which Jesus P. Liao asserted his purchase of the property through a Deed of Omnibus Assignment dated August 23, 1990.
On August 29, 1991, the Court of Appeals annulled the RTC order and canceled the subsequent titles, a decision later reaffirmed in related cases arising from similar facts.
Additional litigation involved respondents (e.g., Susan A. Foronda, Iluminada R. Dionisio, Azucena Q. Pua, Lucia Pua Liok Bin, Edmund Ruiz, Romeo Gomez, and Rosalinda Villapa) who filed complaints and motions in various RTC branches challenging the validity of TCT No. 348292, leading to decisions citing prevailing earlier registrations.

Questions arose regarding the validity and timeliness of the sale certificates issued on June 16, 1913, including whether they were sufficiently approved by the relevant government officials.
Matters of double sale emerged, where successive registrations over the same land raised the issue of which registration should prevail.
Estrella Mapa’s prolonged inaction (approximately 56 years from acquisition in 1930 to filing the petition in 1986) contributed to the controversy over her claimed rights in the land.

Whether the Court of Appeals committed an error in upholding the annulment of the RTC order authorizing the issuance of titles based on reconstituted sales certificates and technical descriptions.

Did the RTC order validly serve as a basis for the issuance of transfer titles in light of conflicting earlier titles?
Were the sale certificates (dated 1913) valid and capable of serving as the source documents for title registration several decades later?
Does the principle of double sale, which favors an earlier registered title over a later one, preclude petitioner’s claim?
Is the petitioner barred by the lapse of time and inaction, rendering any claim based on the stale nature of the underlying sale certificates?