Case Digest (G.R. No. 102961-62)
Case Digest (G.R. No. 102961-62)
Facts:
Jesus P. Liao v. Hon. Court of Appeals; G.R. Nos. 102961-62, 107625, 108759; January 27, 2000; Supreme Court First Division; Pardo, J., writing for the Court.
Petitioner Jesus P. Liao challenges several Court of Appeals decisions that annulled an order of the Regional Trial Court (RTC), Quezon City, Branch 99 (LRC Case No. Q-3369 (86), Judge Godofredo Q. Asuncion) directing the Register of Deeds to issue transfer titles to Estrella Mapa over parcels in the Piedad Estate, Quezon City. The controversy arose because multiple Torrens titles covering the same lots were issued to different persons.
On March 5, 1986, Estrella Mapa filed with the RTC, Branch 99, a petition for reconstitution of documents and issuance of certificates of title over parcels covered by OCT No. 614 (Friar Lands Act, Public Act No. 1120). She claimed original certificates of sale (Nos. 780, 781, 783) issued by the Director of Lands in 1913 and an assignment to her dated April 12, 1930. After hearing, the RTC on June 30, 1986 ordered the Registry of Deeds of Quezon City to issue transfer certificates of title; the Registry issued TCT No. 348156 (Aug. 5, 1986), later cancelling it and issuing TCT Nos. 348291 and 348292 (Aug. 12, 1986) covering Lot 778 and a portion of Lot 777 respectively.
The issuance produced conflicts with preexisting titles. The Land Registration Commission’s (Verification Committee) investigation and the National Bureau of Investigation reports concluded that TCT No. 348292 was fraudulently and irregularly issued as a duplication, recommending annulment and criminal/administrative probes. Meanwhile, Estrella Mapa assigned her interests to Palmera Agricultural Realty Development Corporation, and Palmera later assigned to petitioner Jesus P. Liao (Deed of Omnibus Assignment dated Aug. 23, 1990).
The factual disputes spawned multiple suits and appeals. In CA-G.R. SP Nos. 20381 & 22098 (consolidated), I.C. Cruz Construction, Inc. and Arle Realty Development Corporation sought annulment of the June 30, 1986 RTC order before the Court of Appeals; on August 29, 1991 the Court of Appeals declared that RTC order null and void and ordered cancellation of TCT Nos. 348156, 348291 and 348292 (and subsequent titles). Petitioner Liao moved for reconsideration which was denied, and he filed the present recourse on January 17, 1992.
In Civil Case No. Q-52899 (RTC, Branch 85) respondents Susan A. Foronda, Iluminada R. Dionisio, Azucena Q. Pua and Lucia Pua Liok Bin sued for annulment of title and reconveyance, alleging that Lot 777 had earlier been conveyed to others and that TCT No. 348292 overlapped titles issued as early as 1958 and 1967. The RTC (July 24, 1990) declared TCT No. 348292 null and void and ordered reconveyances; on appeal the Court of Appeals (CA-G.R. SP No. 28422) dismissed the appeal (Oct. 23, 1992), noting that the earlier CA annulment of the June 30, 1986 order had removed the basis for the contested titles. Petitioner filed his Supreme Court recourse on Dec. 16, 1992.
In Civil Case No. Q-52869 (RTC, Branch 105) plaintiffs Edmund Ruiz, Romeo Gomez and Rosalinda Villapa obtained judgment (Sept. 22, 1989) declaring their TCTs valid and TCT No. 348292 null insofar as it overlapped their lots, and directed further action by the Solicitor General and relevant agencies. Petitioner Liao sought annulment of judgment before the Court of Appeals (CA-G.R. SP No. 28368), which denied due course to his petition on Feb. 4, 1993. Petitioner then elevated the matter to the Supreme Court (petition filed Feb. 16, 1993). The three appeals were resolved together by the Court in the decision under review.
Issues:
- Did the Court of Appeals err in upholding the annulment of the RTC Order dated June 30, 1986 (LRC Case No. Q-3369 (86)) and the cancellation of the transfer certificates of title issued pursuant thereto, which had been based on reconstituted sales certificates and technical descriptions?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)