G.R. No. 233767 - Heirs of Elliot vs. Corcuera

A deed of donation covering several parcels of land was executed by the petitioner in favor of his children on July 15, 1987.
The deed was sent by registered mail to the Register of Deeds of Romblon on September 9, 1988.
It was entered in the primary entry book of the Register of Deeds on September 20, 1988 under Entry No. 181.

The Register of Deeds suspended the registration of the donation pending proper clearances from the Department of Agrarian Reform (DAR).
The basis for the suspension was Section 6 of Republic Act No. 6657, which provided that any disposition of private agricultural lands executed prior to June 15, 1988 must be registered within three (3) months after the effectivity of the Act—i.e., on or before September 13, 1988—to be valid.

The petitioner elevated the matter en consulta with the Administrator of the Land Registration Authority (LTA).
On November 27, 1990, the LTA Administrator issued a resolution sustaining the deed registration suspension, insisting that the proper clearances from the DAR were necessary before registration could proceed.
The petitioner then filed a petition for certiorari, arguing that Section 1, Rule 13 of the Rules of Court should be applied suppletorily, so that the date of mailing (September 9, 1988) would be considered the effective date of filing of the document in the Register of Deeds.

Section 6 of Republic Act No. 6657 (approved on June 10, 1988) mandates a three-month registration period for transactions executed prior to its effectivity, which commenced on June 15, 1988.
Section 56 of Presidential Decree No. 1529 requires that all instruments filed with the Register of Deeds, upon payment of the entry fee, are to be recorded with the date, hour, and minute of their reception, which is regarded as the date of registration.
Section 34 of Presidential Decree No. 1529 permits the Rules of Court to be applied by analogy or suppletorily to land registration cases when consistent with the provisions of the decree.

Section 1, Rule 13 of the Rules of Court provides that filing by registered mail is deemed to be effective on the date the document is mailed, as shown by the post office stamp or registry receipt.
The petitioner contended this same rule should be applied to determine the filing and registration date of the deed of donation.

Whether or not Section 1, Rule 13 of the Rules of Court should be applied in a suppletory manner to land registration cases under Presidential Decree No. 1529.

Can the date of mailing, evidenced by the post office stamp, be considered as the effective date of filing and registration even if the actual receipt by the Register of Deeds occurs later?
Does the timing provision of Republic Act No. 6657—which requires registration within three (3) months after the act’s effectivity—affect the validity and enforcement of the registration if the document is mailed earlier?

Whether the delayed physical receipt (September 20, 1988) should override the date of mailing (September 9, 1988) in the registration process of the deed of donation.
The issue of whether deferring registration until obtaining DAR clearances is consistent with the rules on filing dates as provided in the Rules of Court.