Case Digest (G.R. No. 172892)
Facts:
Register of Deeds of Negros Occidental and the National Treasurer of the Republic of the Philippines, petitioners, filed G.R. No. 171804; the Supreme Court Second Division promulgated its decision on August 05, 2015, Leonen, J., writing for the Court. The respondents are Oscar Anglo, Sr. and Anglo Agricultural Corporation (represented by Oscar Anglo, Jr.).In 1960 Alfredo V. de Ocampo applied to register two parcels (Lot No. 2509 of Escalante and Lot No. 817 of Sagay). The Republic (Bureau of Education) contested the registration, claiming the lots had been bequeathed to it and that it held TCT No. 6014. Despite the contest, on August 3, 1965 the Court of First Instance ordered registration in favor of de Ocampo and OCT No. 576‑N issued on October 1, 1965. The Republic filed a Petition for Relief from Judgment (Dec. 28, 1965); that petition was dismissed by the Court of First Instance in San Carlos City on August 20, 1967, and the Court of Appeals initially dismissed the Republic’s appeal on August 21, 1969. The Republic later sought relief before the Supreme Court (Republic v. Court of Appeals, G.R. Nos. L‑31303‑04), and this Court remanded the matter to the Court of Appeals for disposition on the merits (May 31, 1978); proceedings were reinstated July 29, 1983.
While registration litigation continued, de Ocampo entered into a conditional sale with Oscar Anglo, Sr. (June 15, 1962) and later sold Lot No. 2509 and part of Lot No. 817 (Lot 817‑D) to Anglo, Sr. on January 6, 1966; the deed was registered and OCT No. 576‑N was cancelled and TCT No. T‑42217 was issued to Anglo, Sr. Notices of lis pendens were annotated on March 3 and August 24, 1966. Anglo, Sr. conveyed the properties to Anglo Agricultural Corporation on May 17, 1976 in exchange for shares; that deed originally shifted risk to the transferee but was amended on June 7, 1976 so Anglo, Sr. assumed liabilities arising from any adverse decision. After the Court of Appeals reversed the registration in favor of the Bureau of Education and ordered cancellation of OCT/TCT covering the properties (dispositive portion rendered upon remand), the Regional Trial Court ordered surrender of TCT No. T‑88727 (Aug. 20, 1984) and the title was surrendered.
On April 5, 1988 Anglo, Sr. and Anglo Agricultural Corporation filed a Complaint for Recovery of Damages from the Assurance Fund against the Register of Deeds of Negros Occidental and the National Treasurer, alleging they acquired the lots in good faith and without negligence and seeking compensation under Act No. 496 and Presidential Decree No. 1529. At trial (RTC, Bacolod City) respondents presented evidence; petitioners filed no evidence but submitted a memorandum. On November 29, 1995 the RTC (Branch 51) awarded P6,623,617.00 (fair market value computed per Sec. 97, PD 1529) and P20,000 attorney’s fees. The Court of Appeals, in CA‑G.R. CV No. 56925, affirmed t...(Subscriber-Only)
Issues:
- Are respondents Oscar Anglo, Sr. and Anglo Agricultural Corporation entitled to recover damages from the Assurance Fund under Section 95 of Presidential Decree No. 1529?
- Were respondents required to implead Alfredo V. de Ocampo in their Complaint for recovery of damages from the Assurance Fund, and if not, did the...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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