Case Digest (G.R. No. 233578)
Facts:
Republic of the Philippines v. Heirs of Julian Sta. Ana and Mercedes Sta. Ana, G.R. No. 233578, March 15, 2021, Supreme Court Second Division, Lazaro-Javier, J., writing for the Court. The petition seeks review of the Court of Appeals Decision dated August 14, 2017 in CA-G.R. SP No. 139385, which affirmed the Regional Trial Court (RTC), Branch 155, Pasig City, Order directing the Land Registration Authority (LRA) to issue a title over Lot 459, Pasig Cadastre, Psc-14, in favor of the respondents’ predecessors-in-interest.Respondents, the Heirs of Julian Sta. Ana and Mercedes Sta. Ana, filed LRC Case No. N-5999 in the RTC, Pasig, seeking registration of Lot 459. They relied on a final and executory RTC Decision dated October 26, 1967 declaring Julian and Mercedes Sta. Ana the true owners and ordering registration of the lot; that decision had been previously affirmed by the Court of Appeals in CA-G.R. SP No. 24531 by Decision dated October 8, 1991 with entry of judgment on May 19, 1992.
Acting on respondents’ Urgent Ex Parte Motion, the RTC issued an Order for Issuance of Decree dated May 19, 1999 directing the Commissioner of the LRA to comply with Section 39 of Presidential Decree No. 1529 (PD 1529, Sec. 39). The LRA’s Department on Registration, however, filed a Supplementary Report (Oct. 11, 2000) stating that a portion of Lot 459 appeared to be already covered by a certificate of title pursuant to a cadastral decision in Cadastral Case No. 10, Cadastral Record No. 984, and recommended that the applicants submit an amended plan segregating any titled portion to avoid double registration.
The RTC ordered respondents, by Order dated December 5, 2013, to submit the amended plan and technical description. Respondents replied that no copy of the alleged Cadastral Case No. 10 decision or decree could be found in the files of the LRA, DENR, or other agencies, and that attempts to locate records had failed. On August 17, 2014 the RTC granted respondents’ Manifestation and ordered the LRA to issue title for the entire Lot 459 per the 1967 decision, finding that no records of a decision or title in Cadastral Case No. 10 existed; the RTC denied the Republic’s motion for reconsideration on December 9, 2014.
The Court of Appeals, in CA-G.R. SP No. 139385, dismissed the Republic’s petition for certiorari and affirmed the RTC on August 14, 2017, reasoning that the LRA’s notation alone, absent an actual cadastral decision or title in the records, was insufficient to defeat the final and executory 1967 decision and that fact-finding efforts undertaken by the petition...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in affirming the RTC’s directive to issue a registration decree for the entire Lot 459 in favor of the respondents’ predecessors-in-...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)