G.R. No. 166139 - Republic vs. Casimiro

Case Digest (G.R. No. 166139)
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Facts:

Background and Ownership

Respondent Pedro T. Casimiro, claiming to be the registered owner and lawful possessor of Lots 2 and 3 of subdivision plan Psd-57312 in Barrio Payatas, Municipality of Montalban (now part of Quezon City), filed a petition for the reconstitution of the original copy of Transfer Certificate of Title (TCT) No. 305917.
The property had been acquired through a Deed of Absolute Sale dated 24 March 1979, by which respondent purchased the lots from his father, Jose M. Casimiro.
The original title, TCT No. 35359, was cancelled and replaced by TCT No. 305917 in the name of the respondent.

Loss, Destruction, and the Petition for Reconstitution

TCT No. 305917 was lost and destroyed in the fire that devastated the Quezon City Hall Building on 11 June 1988.
On 4 January 1999, respondent filed a Petition for Reconstitution of the original copy of the title before the Regional Trial Court (RTC) of Quezon City, docketed as LRC Case No. Q-11101 (99).
The petition was later amended on 20 November 2000 to include the Quezon City Register of Deeds as a respondent.

Initial RTC Proceedings and Decisions

At the preliminary stage, Solicitor Brigido Luna of the Office of the Solicitor General (OSG) objected to the petition before the RTC regarding the jurisdictional requirements.
On 24 May 2001, the RTC rendered a Decision denying the petition for failure to comply with Section 3 of Republic Act (RA) No. 26.
Respondent filed a Motion for Reconsideration, and on 22 October 2001, the RTC reversed its earlier ruling and granted the petition on the condition that:

The Quezon City Register of Deeds verify the authenticity of the “Owner’s Duplicate Certificate” (the duplicate original) of TCT No. 305917.
There be no other title or duplicate certificate in the Register of Deeds covering the same area.

Subsequent Developments and Evidentiary Challenges

An Entry of Judgment was issued on 12 November 2001; however, complications arose when the petitioner (Republic of the Philippines) filed a Notice of Appeal.
The petitioner claimed that the RTC had already lost jurisdiction due to the perfection of its appeal and time lapse for respondent’s counter-affidavit.
During ensuing hearings, the Quezon City Register of Deeds and the Land Registration Authority (LRA) submitted findings that questioned:

The authenticity of the owner’s duplicate certificate based on discrepancies between the issuance date of TCT No. 305917 and the associated Judicial Form No. 3842367.
The possibility of overlapping titles, particularly a conflicting title issued to the National Government.

Respondent presented a Certification from Edelmira N. Salazar, LRA Administrative Officer IV, which clarified the correct issuance date, thereby rebutting the adverse LRA findings.

Amended RTC Decisions and the Role of the NBI

On 17 January 2002, the RTC issued an Amended Decision that:

Recalled and nullified the October 22, 2001 decision.
Directed that the subject petition be denied due to jurisdictional non-compliance.
Ordered the Quezon City Register of Deeds to turn over its findings to the National Bureau of Investigation (NBI) for an investigation into the alleged fraudulent issuance of TCT No. 305917.

Further, on 6 February 2002, the RTC issued a Resolution denying the petitioner’s Notice of Appeal, contending that the decision was still conditional and not final.

Appeal Before the Court of Appeals and Final Procedural Rulings

The petitioner filed a Petition for Certiorari and Mandamus before the Court of Appeals, seeking:

A writ of preliminary mandatory injunction directing elevation of the case records.
Nullification of the Entry of Judgment and the subsequent Resolution.

The Court of Appeals, on 17 March 2003, ruled that a timely filed Notice of Appeal prevented the RTC decision from becoming final and executory.
Ultimately, in its Decision dated 18 November 2004 (CA-G.R. CV No. 78436), the Court of Appeals:

Affirmed, with modifications, the RTC order reconstituting TCT No. 305917.
Deleted the directive requiring the Register of Deeds to verify the owner’s duplicate certificate.
Ruled that the documentary evidence presented substantially complied with the requirements under Section 3(f) of RA No. 26.

Documentary Basis and the Legal Framework

The reconstitution of TCTs is governed by Section 3 of RA No. 26 and supplemented by sections of Presidential Decree No. 1529 (Property Registration Decree) and RA No. 6732.
The law mandates that when all statutory requirements—such as publication of notices and presentation of the owner’s duplicate certificate—are satisfied, the court must order the reconstitution.
Despite the petitioner’s objections regarding the alleged insufficiency and questionable authenticity of the supporting documents, the factual findings of the RTC and Court of Appeals established that respondent had met all jurisdictional and evidentiary requirements.

Issues:

Jurisdictional Validity

Whether the RTC retained jurisdiction to grant the petition for reconstitution despite the petitioner’s timely Notice of Appeal.
Whether the subsequent orders (Entry of Judgment and Resolution) could be sustained given the pending appeal and alleged loss of jurisdiction.

Sufficiency and Authenticity of Documentary Evidence

Whether the owner’s duplicate certificate, along with other supporting documents (e.g., Deed of Absolute Sale, prior TCT, survey plans, tax declarations), complied with the requirements of Section 3(f) of RA No. 26.
Whether discrepancies in the dates of issuance—specifically, between the Judicial Form No. 3842367 and TCT No. 305917—undermine the reconstitution process.

Impact of Procedural Irregularities

Whether the administrative findings of the LRA, which questioned the issuance dates and potential overlapping of titles, should preclude the reconstitution of TCT No. 305917.
Whether treating the petitioner’s Notice of Appeal as a Motion for Reconsideration affected the substantive rights of the registered owner.

The Mandatory Nature of the Reconstitution Order

Whether the court was compelled to reconstitute the lost title once all statutory and evidentiary prerequisites were satisfied, regardless of technical or administrative discrepancies.

Ruling:

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Ratio:

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Doctrine:

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