G.R. No. 247564 - Manarin vs. Manarin

On June 5, 1997, respondent heirs—Leoncia, Eliza, Francisca, Domingo, and Obdulia Manarin—executed an extrajudicial settlement of the estate of their late father, Fermin Manarin, adjudicating to themselves a 504,286-square meter property in Carmona, Cavite covered by Transfer Certificate of Title (TCT) No. T-741686.
Petitioner Serafin Manarin, also an heir of Fermin, was excluded in this settlement.
Petitioner filed a Complaint for Annulment of Deed of Extrajudicial Settlement of Estate, Cancellation of Title, and Declaration as Heir against the respondent heirs before the Regional Trial Court (RTC).

On November 15, 2005, the parties entered into a Compromise Agreement stipulating that: (a) all are legitimate heirs; (b) the subject property would be sold or offered as joint venture; (c) proceeds would be shared equally; and (d) Danilo Sayarot, the financer of the reconstitution of TCT No. T-741686, would turn over the original owner's copy of the title to the parties.
On July 27, 2012, the RTC rendered a decision approving the Compromise Agreement, ordering the parties to comply with its terms. The decision became final and executory on October 2, 2012.

On December 10, 2012, the respondent heirs executed a Special Power of Attorney (SPA) in favor of Fely Panganiban to take custody and possession of the owner's duplicate copy of the TCT, which was annotated on the title.
Petitioner filed an omnibus motion on July 4, 2013, praying for: correction of the incorrect TCT number in the decision, issuance of a writ of execution, and cancellation of the SPA annotation.
September 26, 2017 RTC Order: The court corrected the TCT number to T-741686, ordered Danilo to turn over the original title to the RTC for custody pending sale, but denied cancellation of the SPA annotation.
April and May 2018: Petitioner’s motion for execution was granted, and writ of execution issued; however, the sheriff’s report revealed Danilo did not have possession of the owner’s copy.

June 8, 2018 RTC Order: Declared TCT No. T-741686 lost and of no force due to Danilo’s non-possession; ordered issuance of a new owner’s copy by the Register of Deeds to be turned over to the RTC.
June 27, 2018 Manifestation: Register of Deeds informed the RTC that Fely had possession of the owner’s duplicate title, not lost.
June 28, 2018 Motion: Respondent heirs moved to nullify or recall issuance of new title, claiming title was not lost but with Fely.
July 13, 2018 RTC Order: Directed Fely to surrender the owner’s duplicate title to the Clerk of Court, warning that failure to surrender would result in declaration of the title as lost and issuance of new title. Emphasized Fely is not a party and not authorized to have the title per the RTC Decision.
July 25, 2018 Omnibus Motion by respondents sought to nullify all proceedings related to the lost title motion, cancel writ of execution, and recall the July 13, 2018 Order.
August 31, 2018 RTC Order denied respondents’ omnibus motion, declared the title lost due to Fely’s refusal to surrender, and ordered issuance of new owner’s duplicate title to be held by the Clerk of Court. The order was immediately executory.

Respondents filed a Petition for Certiorari with the CA assailing the RTC’s orders.
Petitioner manifested that the Register of Deeds had issued a new owner’s duplicate copy of the title pursuant to RTC orders and deposited it with the Clerk of Court.
March 28, 2019 CA Decision: Granted the petition, nullified the September 26, 2017, June 8, 2018, July 13, 2018, and August 31, 2018 RTC Orders, Writ of Execution of May 11, 2018, and the November 3, 2017 Certificate of Finality. Held that the RTC lacked jurisdiction to amend the final July 27, 2012 Decision or issue orders substantially altering it.
CA ruled the amendment correcting the TCT number and the orders directing delivery of the owner’s copy to the court clerk deviated from the terms of the Compromise Agreement.
Denied petitioner’s motion for reconsideration in May 2019.

Petitioner filed this petition for review on certiorari challenging the CA’s decision and resolution.
Petitioner raised procedural and substantive issues claiming the RTC orders were proper for faithful execution of the final judgment and conform to the Compromise Agreement.
Respondent heirs argued the petition was procedurally infirm and the RTC orders were void for failing to comply with applicable property registration laws and their SPA confers rightful possession on Fely.

Whether the Court of Appeals committed reversible error in giving due course to respondent heirs’ Petition for Certiorari despite procedural infirmity (non-filing of motion for reconsideration before RTC).

Whether the Court of Appeals erred in declaring the RTC committed grave abuse of discretion in issuing the orders subsequent to the July 27, 2012 Decision.

Whether the RTC orders conform with the Compromise Agreement and pursue expeditious administration of justice.

Whether the issuance of a new owner’s duplicate TCT should strictly follow the procedural requirements under Section 109 of Presidential Decree No. 1529 (Property Registration Decree).