G.R. No. 87653 - Aquino vs. National Labor Relations Commission

The Republic of the Philippines filed a Petition for Review under Rule 45 assailing the Court of Appeals Decision dated August 14, 2017 in CA-G.R. SP No. 139385, which dismissed the Republic’s petition for certiorari and affirmed the Regional Trial Court’s directive to the Land Registration Authority (LRA) to issue a title over Lot 459, Pasig Cadastre, Psc-14 in favor of the heirs of Julian Sta. Ana and Mercedes Sta. Ana.
The subject matter is LRC Case No. N-5999, an application by the respondents (heirs) for registration of Lot 459 based on a final and executory October 26, 1967 decision declaring their predecessors-in-interest the true and absolute owners and ordering registration.

In March 1999, respondents filed an urgent ex parte motion for issuance of decree, invoking the 1967 decision. The trial court granted the motion on May 19, 1999, directing the Commissioner of the LRA to issue the decree and certificate of title under Section 39 of PD 1529.
The LRA, through its Director on Registration, reported that a portion of Lot 459 was already covered by a certificate of title pursuant to Cadastral Case No. 10, Cadastral Record No. 984, and recommended submission of an amended plan segregating the titled portion.
By Order dated December 5, 2013, the trial court directed respondents to submit an amended plan and technical description. Respondents filed a manifestation and motion for reconsideration, asserting they could not locate any copy of the supposed Cadastral Case No. 10 decision or title.
By Order dated August 17, 2014, the trial court granted respondents’ motion, finding no existing records of the prior title and ruling that issuance of a decree covering the entire lot would not result in duplication. It denied the Republic’s motion for reconsideration on December 9, 2014.

The Republic petitioned for certiorari, contending that the decree would duplicate titles. The CA noted that despite diligent efforts, respondents could not produce any record of Cadastral Case No. 10 or the supposed title.
The CA held that factual findings of the lower court, supported by substantial evidence, are final; that a certiorari petition cannot be used for fact-finding; and that the LRA’s lack of records negated any duplication risk. It dismissed the petition and affirmed the trial court’s order.

The Republic filed a Rule 45 petition, reiterating arguments on overlapping titles and non-compliance with LRA recommendations.
Respondents maintained they exerted all efforts to comply but no records existed; they challenged any third-party claims over the lot portion.
The issue before the Court was whether the CA committed reversible error in affirming the directive to issue a registration decree covering the entire Lot 459.

Whether the Court of Appeals erred in affirming the trial court’s directive to issue a registration decree for the entire Lot 459, despite LRA reports of a purported prior title under Cadastral Case No. 10.