G.R. No. 88168 - Traders Royal Bank vs. National Labor Relations Commission

Pilar Estipular, the petitioner below, filed a Petition for Reconstitution of Title before the Regional Trial Court (RTC) of La Union.
She declared she was the sole surviving legal heir of the late Fermin Estipular, who died intestate.
Certificate of Title No. 154 covering a parcel of land in Barrio Liquicia, Caba, La Union, initially issued in the name of Fermin Estipular, was lost or destroyed during the burning of the Register of Deeds of La Union in World War II.
The land was already declared and distributed among ten heirs; the estate was neither mortgaged nor had pending registration cases.

The RTC ordered the publication of the Notice of Hearing twice in the Official Gazette and posting at the main entrance of the Municipal Building of Caba, La Union.
Posting of the Notice of Hearing at the municipal building was duly certified twice by the Branch Sheriff.
Publication in the Official Gazette took place on two successive weeks (October 17 and 24, 1994).
No posting at the main entrance of the provincial capitol building was done.
The Solicitor General, representing the Republic of the Philippines, appeared and filed an appearance; the Public Prosecutor represented the government during hearings.
On December 7, 1994, the initial hearing took place; no private oppositors came forward.
Jurisdictional facts with documentary evidence including certificates of publication and posting were presented on January 24, 1995.
Evidence and testimonies confirmed the destruction of the original title due to wartime burning.
RTC granted the petition and ordered the Register of Deeds of La Union to reconstitute the title in favor of Fermin Estipular with the appropriate annotations.
The Court of Appeals (CA) affirmed the RTC decision despite the lack of posting at the provincial building, ruling that there was substantial compliance with the publication and posting requirements of Republic Act No. 26.

Whether or not substantial compliance with the publication and posting requirements under Republic Act No. 26 is sufficient to confer jurisdiction on the trial court to hear and decide a petition for reconstitution of a lost or destroyed certificate of title.