G.R. No. 172203 - Lopez y Aberasturi vs. People

The People’s Homesite and Housing Corporation (PHHC), predecessor of the National Housing Authority (NHA), was the registered owner of two large parcels of land in the then Municipality of San Juan Del Monte, Province of Rizal (now part of Quezon City).
These parcels, covered by Transfer Certificate of Title (TCT) No. 1356, comprised almost the entire Diliman Estate with an estimated area of 386,732.40 sq. meters and 15,555,534.60 sq. meters.
The estate was subdivided into approximately 17,387 lots through various survey plans; most were already sold and disposed of to beneficiaries, leaving 389 lots where either the lots remained undisposed or contracts had been executed but the individual TCTs were not yet issued.

On June 11, 1988, a fire at the Quezon City Register of Deeds (QCRD) destroyed both the original and the owner’s duplicate of TCT No. 1356 along with other records.
In response, on March 12, 1999, NHA filed a petition for the reconstitution of TCT No. 1356 in the Regional Trial Court (RTC) Branch 227 in Quezon City.
NHA attached several documentary evidences including:

A photocopy of the technical description issued by the Lands Management Bureau (DENR).
Subdivision Plan No. BSD 7365.
Certification from QCRD confirming the destruction of TCT No. 1356 in the fire.
A photocopy of TCT No. 1356 from NHA’s Estate Management Title Custodian.
A detailed list of the remaining 389 lots with pertinent lot and block details.

The RTC set the petition for initial hearing on April 13, 1999, directing NHA to submit multiple certified true copies and originals of annexes including tax declarations, tax receipts, and other jurisdictional documents.
NHA failed to comply with the RTC’s directive and did not appear at the initial hearing, prompting the RTC to archive the petition on April 13, 1999.
On December 27, 2000, the RTC dismissed the petition for reconstitution as lacking merit, emphasizing that NHA had not complied with the required jurisdictional documents and that no new petition could be filed in another forum regarding TCT No. 1356.

NHA sought reconsideration explaining its readiness to comply with the requirements, except for the certified true copies of tax declarations and receipts yet unfinished by the Quezon City Assessor’s Office.
The RTC set the motion for reconsideration on May 8, 2001, and directed further compliance to show good faith.
Despite submitting additional copies of documents and a letter from the Assessor’s Office, the RTC issued orders on May 30, 2001, and June 29, 2001, which denied the motion for reconsideration for lack of merit.
The orders addressed that the failure to present additional requisite documentation and the filing delays effectively barred NHA from proceeding via reconstitution.

NHA had filed a notice of appeal after the denial of its motion for reconsideration; however, the RTC dismissed the appeal due to its untimely filing.
The untimeliness was based on the reglementary period interruption caused by the motion for reconsideration which left only one day for filing the notice of appeal—a deadline that NHA failed to meet.
NHA subsequently filed a petition for certiorari in the Court of Appeals (CA), alleging grave abuse of discretion by the RTC and challenging both the dismissal on appeal and the procedural deficiencies noted.

Whether the CA erred in dismissing NHA’s petition for certiorari on technical grounds due to the failure to attach all relevant pleadings and documents as required by Rule 65 and Section 3, Rule 46 of the Rules of Court.

Whether the RTC committed grave abuse of discretion by dismissing NHA’s petition for reconstitution for lack of merit and by subsequently ruling on the timeliness of its notice of appeal.
Whether the dismissal of the petition for reconstitution, though with prejudice, should prevent NHA from filing a new petition for reconstitution of TCT No. 1356.

Whether the RTC correctly calculated the reglementary period for filing the notice of appeal after the motion for reconsideration was filed and then denied.
Whether the application of appellate period rules, including the interruption caused by the motion for reconsideration, was done in accordance with prevailing jurisprudence.