Title
Luriz vs. Republic
Case
G.R. No. 208948
Decision Date
Feb 24, 2016
The Supreme Court dismissed a petition for reconstitution of a lost Transfer Certificate of Title, ruling that the petitioner failed to prove the authenticity of the title and that reconstitution proceedings do not determine ownership of the land.
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Case Digest (G.R. No. 208948)

Facts:

  • Jose B. Luriz aimed to reconstitute lost Transfer Certificate of Title (TCT) No. 1297 from the Quezon City Registry of Deeds.
  • The title was initially issued to Yoichi Urakami and encompassed two lots totaling around 3,033.5 square meters.
  • Luriz filed an amended petition for reconstitution on May 26, 1997, asserting that Urakami sold the properties to Tomas Balingit in 1948, who subsequently sold them to Luriz in 1975.
  • The original TCT was lost in a fire at Quezon City Hall in June 1988.
  • Luriz relied on an owner's duplicate copy of the TCT to support his petition.
  • The Regional Trial Court (RTC) found the petition sufficient and scheduled a hearing, requiring notice publication in the Official Gazette.
  • The Republic of the Philippines contested the petition, claiming ownership through various documents, including Vesting Order No. P-89, which confiscated properties of Japanese nationals after World War II.
  • In December 2009, the RTC ruled in favor of Luriz, permitting the reconstitution of the title.
  • The Republic appealed to the Court of Appeals (CA), which reversed the RTC's decision in May 2013.
  • Luriz later filed a petition for review with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the Court of Appeals' decision, dismissing Luriz's petition for reconstitution.
  • The Court determined that Luriz did not prove the authenticity of the title he sought to reconstitute....(Unlock)

Ratio:

  • The purpose of reconstituting a certificate of title is to restore a lost or destroyed title, necessitating clear proof of its validity at the time of loss.
  • Luriz failed to establish the authenticity of TCT No. 1297, particularly in light of Vesting Order No. P-89, which stripped Urakami of any titl...continue reading

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