Facts:

• On February 16, 1999, Dominador Santua filed a petition for judicial reconstitution of Transfer Certificate of Title (TCT) No. T-22868 with the Regional Trial Court (RTC) of Calapan, Oriental Mindoro.
• Santua claimed ownership of parcels of land totaling 3,306 square meters located in Poblacion, Victoria, Oriental Mindoro, covered by TCT No. T-22868.
• The original copy of the title was destroyed in a fire on August 12, 1977, which razed the Capitol Building housing the Office of the Register of Deeds of Oriental Mindoro.
• The owner's duplicate copy was lost during an earthquake on November 15, 1994.
• Santua asserted that there were no co-owner's, mortgagee's, or lessee's duplicate copies, no buildings or improvements on the land that did not belong to him, and no deeds or instruments affecting the property pending registration.
• He and his family were in actual possession of the property and had been paying taxes on it.
• The petition included a tax declaration, survey plan, and technical descriptions of the lots.
• The RTC issued an order for the initial hearing and directed the publication and notification of the order.
• Santua complied with the jurisdictional requirements and presented various documents, including the tax declaration, technical descriptions, and a certification from the Acting Register of Deeds.
• The RTC granted the petition on December 15, 2000, directing the reconstitution of the title.
• The Office of the Solicitor General appealed, and the Court of Appeals (CA) affirmed the RTC decision on September 23, 2002.
• The Republic of the Philippines then filed a petition for review with the Supreme Court.

Issue:

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Ruling:

• The Supreme Court granted the petition, reversed and set aside the CA decision, and denied ...(Unlock)

Ratio:

• The Supreme Court emphasized that the reconstitution of a certificate of title involves restoring a lost or destroyed instrument attesting to a person's title to a piece of land.
• This process must be based on clear proof that the title was indeed issued to the petitioner.
• Section 3 of Republic Act (R.A.) No. 26 enumerates the valid and sufficient bases for reconstitution, which include the owner's duplicate, co-owner's, mortgagee's, or lessee's duplicate, a certified copy of the certificate of title, the deed of transfer or other document on file in the registry of deeds, and any other document deemed sufficient by the court.
• The Court noted that the documents enumerated in Section 3 are highly credible as they ...continue reading