Case Digest (G.R. No. L-67451)
Facts:
Realty Sales Enterprise, Inc. and Macondray Farms, Inc. v. Intermediate Appellate Court (Special Third Civil Cases Division), Hon. Rizalina Bonifacio Vera, as Judge, Court of First Instance of Rizal, Branch XXIII; Morris G. Carpo; Quezon City Development and Financing Corporation; and Commissioner of Land Registration, G.R. No. 67451, September 28, 1987, Supreme Court Third Division, Cortes, J., writing for the Court.
The dispute involves two adjacent parcels in Almanza, Las Piñas (totaling 373,868 sq. m.) that were the subject of multiple Torrens registrations. There are three competing title lines: (1) TCT No. 20408 (Realty), derived from OCT No. 1609 issued pursuant to Decree N‑63394 from earlier LRC proceedings (LRC Case No. 657, joined with Nos. 758 and 976); (2) TCT No. 303961 (Morris G. Carpo), derived from OCT No. 8629; and (3) TCT Nos. 333982 and 333985 (Quezon City Development and Financing Corporation, QCDFC), derived from OCT No. 8931.
On December 29, 1977 Carpo filed an action in the Court of First Instance (CFI) of Rizal, Branch XXIII (presided by Judge Rizalina Bonifacio Vera) seeking annulment of Decree N‑63394 and TCT No. 20408. The complaint alleged that the Reyes Court (CFI‑Rizal, Branch VI) which issued the May 21, 1958 order directing issuance of a decree of registration (substituting Dominador Mayuga for the earlier adjudicatee Estanislao Mayuga) acted not as a land registration court and thus lacked jurisdiction, and that original LRC records had been lost and were pending reconstitution. Realty and Macondray answered and filed a third‑party complaint against QCDFC and the Commissioner; QCDFC counterclaimed and later filed a fourth‑party complaint but failed to prosecute it.
After trial, the Vera Court rendered judgment on January 20, 1981 sustaining Carpo’s title and declaring Realty’s and QCDFC’s titles null and void. Realty petitioned for certiorari to the Supreme Court (docketed G.R. No. L‑56471) on March 20, 1981, asking to appeal directly to the Court on questions of law; by resolution dated October 19, 1981 the Supreme Court referred the case to the Court of Appeals “in aid of its appellate jurisdiction.”
The Court of Appeals (Ninth Division) on December 29, 1982 set aside the CFI judgment and held Realty’s title valid while declaring Carpo’s and QCDFC’s titles void. Carpo moved for reconsideration. Meanwhile, by virtue of Batas Pambansa Blg. 129 the Court of Appeals was reorganized into the Intermediate Appellate Court (IAC), triggering re‑raffling and reassignment of the case. After several reassignments the matter was before the IAC Special Third Civil Cases Division, which, by Resolution dated May 2, 1984, granted Carpo’s motion for reconsideration, reversed the Court of Appeals decision of December 29, 1982, and affirmed the Vera Court decision. Realty and Macondray filed the present petition (G.R. No. 67451) to set aside the IAC Resolution and reinstate the Court of Appeals decision.
Petitioners raised multiple assignments of error, principally that (1) the IAC Special Third Civil Cases Division was not properly constituted under BP 129 (Secs. 4, 8) and therefore lacked jurisdiction; (2) the IAC erred...(Pro-only)
Issues:
- Under Batas Pambansa Blg. 129, did the IAC Special Third Civil Cases Division have jurisdiction and adjudicatory power to promulgate the Resolution of May 2, 1984?
- Could the Court of Appeals’ Decision of December 29, 1982 operate as a valid appellate determination given the procedural posture (petition for review on certiorari referred by the Supreme Court), and did the July 25, 1983 Resolution of the Court of Appeals “erase or cancel” that Decision?
- Was the May 21, 1958 order of the Reyes Court (directing issuance of a decree of registration in favor of Dominador Mayuga) valid despite the alleged loss of original LRC records and failure to reconstitute?
- Did Morris G. Carpo qualify as an innocent purchaser for value whose later Torrens title would prevail over the earlier title claimed by Realty (derived from Mayuga)?
- Is QCDFC’s t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)