Case Digest (G.R. No. 240331)
Facts:
Republic of the Philippines, represented by the Department of Transportation (DOTr) v. Guillerma Lamaclamac and the Land Registration Authority (LRA), G.R. No. 240331, March 16, 2022, the Supreme Court Third Division, Lopez, J., writing for the Court.The petition arose from a Complaint for Cancellation of Decree filed by the Republic of the Philippines, represented by the DOTr, against Guillerma Lamaclamac and the LRA before the Regional Trial Court (RTC) of Initao, Misamis Oriental, Branch 44 (MC Case No. 2008-736). The subject was Lot No. 12446, Cadastral No. 27 (9,386 sq. m.) in Alubijid, Misamis Oriental, over which the cadastral court issued Decree No. 756523 in favor of Lamaclamac on August 26, 1941.
Lamaclamac died in 1947; her heirs later disposed of the lot to the government and the parcel is now used for the Laguindingan Airport Development Project. In 2006 the LRA Administrator issued a certification stating that certain decrees, including Decree No. 756523, were not among the salvaged decrees on file and were presumed lost or destroyed during World War II. The Registrar of Deeds of Misamis Oriental issued a similar certification in 2007, suggesting that original titles, if previously issued, may have been destroyed or lost and recommending reconstitution rather than cancellation.
Relying on those certifications, the DOTr alleged before the RTC that Lamaclamac had abandoned any right to the subject lot and that laches barred her claim because no certificate of title was found on record after many decades. Lamaclamac did not file a responsive pleading and was declared in default; the LRA filed a Manifestation asserting the certifications did not categorically state no title had ever been issued and that a title may have been lost or destroyed.
The RTC dismissed the Complaint for Cancellation of Decree for insufficiency of evidence (Decision dated June 26, 2015), holding that issuance of a decree vests ownership and the LRA has a ministerial duty to issue the certificate of title, so laches did not apply. The RTC denied the DOTr’s motion for reconsideration (Order dated July 12, 2016). The Office of the Solicitor General appealed to the Court of Appeals (CA), which, in its Decision dated June 21, 2018 (CA‑G.R. CV No. 04...(Pro-only)
Issues:
- Did the Court of Appeals gravely err in affirming the RTC’s dismissal of the Complaint for Cancellation of Decree on the ground that there was insufficient evidence that Decree No. 756523 had been transcribed in the Register of Deeds and that the corresponding certificate o...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)