G.R. No. 271741 - Sinsuat, et al. vs. Ebrahim, et al.

The petitioners (Heirs of Homer L. Barque, represented by their attorney‐in‐fact, Rosa R. Manotok) sought the administrative reconstitution of TCT No. 210177, originally issued in the name of Homer L. Barque, Sr.
The title was allegedly destroyed in the 1988 fire at the Quezon City Hall, which affected the Register of Deeds’ office.
In support of the petition, the petitioners submitted the owner’s duplicate certificate of title, real estate tax receipts, tax declarations, and Plan FLS 3168-D covering the property.

The private respondents (the Manotok family, owners of TCT No. RT-22481) opposed the petition, alleging that the land covered by TCT No. 210177 was already registered under their title.
They contended that the owner’s duplicate certificate belonged to their reconstituted title and asserted that TCT No. 210177 was spurious.
The opposition highlighted discrepancies in the technical description and boundaries of the property, claiming duplication with Lot 823 Piedad Estate.

On June 30, 1997, Atty. Benjamin M. Bustos, acting as the reconstituting officer, denied the petition for reconstitution on two grounds:

Lot 823-A and 823-B (as shown in Plan FLS 3168-D), with areas nearly equal to the whole lot of 823 Piedad Estate covered by TCT No. 372302, indicated duplication.
The submitted Plan FLS 3168-D was considered spurious following the categorical statement by Engr. Privadi J.G. Dalire of the Geodetic Surveys Division.

Petitioners’ subsequent motion for reconsideration was denied, prompting an appeal to the Land Registration Authority (LRA).
The LRA reversed the reconstituting officer’s decision, ruling that only the owner’s duplicate certificate of title was required as a basis for reconstitution per Section 3 of RA No. 26.
The LRA declared that TCT No. 210177 was valid, genuine, authentic, and effective, and should be reconstituted—subject to canceling the conflicting TCT No. RT-22481 by a court of competent jurisdiction.

In CA-G.R. SP No. 66700, the Special Division initially ordered the cancellation of TCT No. RT-22481 and directed immediate reconstitution of TCT No. T-210177.
In CA-G.R. SP No. 66642, the Third Division affirmed the LRA’s ruling which had denied due course to the reconstitution pending resolution by a Regional Trial Court (RTC) on the conflicting title.

A subsequent motion for reconsideration led the Third Division (on February 24, 2004) to grant relief by ordering cancellation of TCT No. RT-22481 and directing the reconstitution of the respondents’ title.
Ultimately, the petitions were consolidated in the Supreme Court under G.R. Nos. 162335 and 162605.

The Manotok petitioners challenged the cancellation of their existing Torrens title, arguing:

The LRA and Court of Appeals acted without jurisdiction by canceling their title in an administrative reconstitution proceeding.
The cancellation constitute a collateral attack on their property without a direct RTC proceeding, violating due process.
The reconstitution of the Heirs of Barque’s title should require a judicial declaration of the petitioners’ title being void.

They further contended that the majority decision misapplied the precedent set in Ortigas v. Velasco, distinguishing their situation from cases involving dual titles.

Whether the LRA has jurisdiction to decide on, and effectively annul, petitioners’ Torrens title within an administrative reconstitution proceeding.
Whether the Court of Appeals properly assumed jurisdiction and exercised equitable powers in ordering the cancellation of TCT No. RT-22481 without a direct RTC proceeding.

Whether the reconstituting officer, by requiring additional documents (such as Plan FLS 3168-D), exceeded his mandate given that Section 3 of RA No. 26 lists the owner’s duplicate certificate of title as the primary source.
Whether the evidence demonstrating the spurious nature of the petitioners’ title was sufficient and appropriately assessed.

Whether the decision improperly allowed a collateral attack on an existing title rather than mandating a direct judicial proceeding in accordance with the rule that title cancellation may only occur in a proper action under BP Blg. 129 and Section 48 of PD 1529.
Whether the application of the ruling in Ortigas v. Velasco was apt in the present controversy.

Whether the petitioners were denied their right to due process by not being afforded an opportunity to present evidence and defend the validity of their Torrens title in a direct judicial proceeding.