G.R. No. 213209 - Republic vs. Susi

On September 27, 2005, Gertrudes V. Susi filed a verified petition before the Regional Trial Court (RTC) of Quezon City, Branch 77, seeking the reconstitution of Transfer Certificate of Title (TCT) No. 118999 covering Lot 25 of Plan Psu-32606 in Barrio (now Barangay) Talanay, Quezon City.
Susi claimed that the original TCT was destroyed in the fire that gutted the Registry of Deeds of Quezon City on June 11, 1988, and her petition was based on the owner’s duplicate copy of the title, docketed under LRC Case No. Q-20493(05).

Set the case for an initial hearing on February 2, 2006;
Directed that the relevant government offices be furnished with a copy of the Order; and
Mandated the publication of the notice in the Official Gazette for two consecutive weeks and its posting at designated public places.

On January 16, 2006, the Land Registration Authority (LRA) filed a Manifestation with the RTC indicating that similar petitions for reconstitution had been filed in other RTC branches (Branches 88 and 220) and accompanied by earlier Reports questioning the authenticity of Susi’s duplicate title.
Susi complied with the jurisdictional requirements on February 2, 2006, and the RTC allowed her to adduce evidence.
The City Government of Quezon City (QC Government) filed an Opposition on February 3, 2006 alleging res judicata; however, it was later held that the QC Government lacked the locus standi to oppose the petition.
The Office of the Solicitor General (OSG) later entered its appearance through its deputized representative, the Office of the City Prosecutor of QC.

On January 12, 2011, the RTC granted Susi’s petition and directed the Registry of Deeds of Quezon City (RD-QC) to reconstitute the lost/destroyed original copy of TCT No. 118999, finding that:

The presentation of the owner’s duplicate copy of the title and the Certification from RD-QC (confirming the destruction of the original during the 1988 fire) was sufficient; and
Any prior dismissal based on technical deficiencies in earlier petitions did not bar the present petition since the objections had been overcome.

Dissatisfied, the QC Government filed a motion for reconsideration, while the Republic, through the OSG, filed a Notice of Appeal. Both actions were initially denied by the RTC.
A subsequent motion to vacate the judgment was filed by the Republic on October 25, 2011, arguing res judicata, and additional interventions were made by other parties including the Sunnyside Heights Homeowner’s Association, Inc.
On March 31, 2011, the LRA filed a Manifestation objecting to the reconstitution, citing doubts about the authenticity of Susi’s duplicate title and emphasizing the need for strict compliance with the procedural and jurisdictional requirements under RA 26.
The RTC, in an Order dated July 5, 2012, denied the Republic’s Motion to Vacate Judgment, holding that the January 12, 2011 Decision had attained finality, and accordingly, a Writ of Execution was issued on July 20, 2012.

The Republic then sought relief by filing a Petition for Certiorari before the CA (docketed as CA-G.R. SP No. 127144), challenging:

The CA, in its Decision dated February 13, 2014, found no reversible error or grave abuse of discretion by the RTC, holding that:

Susi had sufficiently established that TCT No. 118999 was valid and belonged to her; and
The principle of res judicata was inapplicable because the earlier dismissal was based on non-compliance with technical requirements.

A motion for reconsideration filed by the Republic, which included a Resolution from the LRA highlighting issues such as overlapping interests and conflicting certificate serial numbers, was denied by the CA in its Resolution dated June 25, 2014, leading to the present petition.

Whether the Court of Appeals erred in finding that the RTC committed no grave abuse of discretion by:

Denying the Republic’s Motion to Vacate Judgment (Order dated July 5, 2012) in LRC Case No. Q-20493(05); and
Upholding the RTC Decision dated January 12, 2011 granting Susi’s petition for reconstitution of TCT No. 118999.

Whether the RTC and, by extension, the CA properly examined and complied with the mandatory procedural and jurisdictional requirements under Republic Act No. 26, particularly with respect to:

The proper publication and service of notice to interested parties (registered owners, adjacent property owners, and occupants); and
The validity and authenticity of the duplicate title presented by Susi given the conflicting evidence (different serial numbers and earlier LRA reports).