Case Digest (G.R. No. 212388)
Facts:
Republic of the Philippines v. Heirs of Spouses Donato Sanchez and Juana Meneses, represented by Rodolfo S. Aguinaldo, G.R. No. 212388, December 10, 2014, Supreme Court Third Division, Velasco Jr., J., writing for the Court.
The petition arose from an application filed under Republic Act No. 26 for the reconstitution of Original Certificate of Title (OCT) No. 45361 covering Lot No. 854, Dagupan Cadastre. Respondents are the Heirs of Spouses Donato Sanchez and Juana Meneses, represented by Rodolfo S. Aguinaldo; petitioner is the Republic of the Philippines. Respondents alleged that Lot No. 854 had been adjudicated to the spouses Sanchez in a cadastral decision (Decision dated March 12, 1930) and that an OCT No. 45361 had been issued pursuant to Decree No. 418121, but the owner’s copy of the OCT was missing and therefore they could not register an extrajudicial partition among the heirs. They further alleged that the Registers of Deeds (RD) of Lingayen and Dagupan had certified that copies of the decree and OCT could not be found in their records.
The trial court (Regional Trial Court, Branch 40, Dagupan City) gave the petition due course on June 24, 2001 and ordered publication. The Land Registration Authority (LRA) requested the submission of additional supporting documents (RD certification of loss, technical description approved by LRA/LMB, and sepia plan); the case was temporarily archived because respondents initially could not secure all documents but was later revived when they did. Among the evidence respondents eventually submitted were (a) a certified copy of the March 12, 1930 cadastral decision (in Spanish) adjudicating Lot No. 854 to the spouses Sanchez, and (b) a certified copy of the Registrar’s Index Card noting OCT No. 45361 under Donato Sanchez. The LRA filed a report (January 11, 2008) acknowledging that a decree for Lot No. 854 was issued and that the plan and technical description corresponded to the lot, but noting that the copy of the decree was no longer available in its records.
On June 30, 2008 the RTC dismissed the petition for lack of sufficient evidence, holding that RA No. 26 applies only when the issuance of the OCT sought to be reconstituted has been established and that respondents failed to prove that OCT No. 45361 had in fact been issued pursuant to the cited decree. Respondents moved for reconsideration. The RD of Dagupan then manifested that OCT No. 45361 had been superseded by TCT No. 10202 (in the name of Rufino Marinas) which was cancelled by TCT No. 44365 and thereafter by TCT No. 80792 (in the name of Dagupan Doctors Villaflor Memorial Hospital), and that these later titles bore notations that the lot was "originally registered on the 29th day of January, [1931] ... as OCT No. 45361 pursuant to Decree No. 418121" and that "the name of the registered owner of OCT No. 45361 is not available" per RD of Lingayen certification dated August 18, 1982.
On appeal the Court of Appeals (CA) reversed the RTC in a Decision dated November 8, 2013 (CA‑G.R. CV No. 94720), holding that the documentary evidence presented by respondents fell under paragraph (f) of Section 2 of RA No. 26 and citing Republic v. Tuastumban for the proposition that official documents recognizing ownership and its chain can suf...(Pro-only)
Issues:
- Did respondents sufficiently prove that an Original Certificate of Title No. 45361 was issued for Lot No. 854 (a procedural/threshold question under RA No. 26)?
- If an OCT is assumed to have existed, was reconstitution proper given the evidentiary requirement under Section 15 of RA No. 26 that the certificate be "in force at the time it was lost or destroyed," and do the derivative TCTs and RD notations satisfy that requirement (a substantive question u...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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