Case Digest (G.R. No. L-25475)
Facts:
The case of Felicidad Reyes-Talag v. Register of Deeds of Laguna arose from a dispute over the ownership of a parcel of land originally belonging to Numeriano Reyes, who owned 18,755 square meters, covered by Original Certificate of Title No. 187, located in the Municipality of San Pedro, Province of Laguna. On January 9, 1959, the government initiated expropriation proceedings to subdivide and resell the land to bona fide occupants through the Land Tenure Administration. Subsequently, on June 23, 1959, the Court of First Instance of Laguna acknowledged the government's right to expropriate the land but exempted two lots from this proceeding: one measuring 471 square meters, which had been sold to Felicidad Reyes-Talag, and another measuring 1,170 square meters, which had been sold to Jose Oliver. The court's decision was documented and reported as Entry No. 26592 in the Office of the Register of Deeds.After having the land surveyed with the consent of the Land Tenure Administ
Case Digest (G.R. No. L-25475)
Facts:
- Background and Ownership of the Land
- Numeriano Reyes owned an 18,755-square-meter parcel of land covered by Original Certificate of Title No. 187, located in the Municipality of San Pedro, Province of Laguna.
- The land was subject to expropriation proceedings instituted on January 9, 1959, by the government through the Land Tenure Administration for subdivision and resale purposes.
- Expropriation Proceedings and Judicial Decision
- On June 23, 1959, the Court of First Instance of Laguna declared the government's right to expropriate the land.
- Critically, the decision expressly excluded two lots from expropriation:
- One of 471 square meters, which had been sold to Felicidad Reyes-Talag.
- Another of 1,170 square meters, sold to Jose Oliver.
- A certified copy of this expropriation decision was furnished to the Register of Deeds and annotated on the back of the original certificate of title.
- Segregation of the Land and Petition for a New Certificate
- After surveying the property, with the consent of the Land Tenure Administration, Felicidad Reyes-Talag segregated the 471-square-meter lot from the remainder of the land.
- Felicidad then requested the Office of the Register of Deeds to issue a new certificate of title covering her portion as per the court decision.
- The Acting Register of Deeds, however, imposed additional documentary requirements:
- Production of the certificate covering the whole land.
- A document proving that Numeriano Reyes had transferred the land to her.
- A public acknowledgment from Numeriano Reyes confirming the transfer.
- After Numeriano Reyes’ death (August 8, 1962), presentation of his death certificate.
- A deed of confirmation from the heirs of Numeriano Reyes.
- Compliance with Requirements by Felicidad Reyes-Talag
- Numeriano Reyes executed a public instrument acknowledging the transfer in favor of his daughter.
- Following Numeriano Reyes’ death, the heirs complied by executing a deed of confirmation on September 4, 1964:
- The deed was signed by Reyes' widow (in her capacity both as wife and as guardian of five minors), by an attorney-in-fact (for three minors), and by six children already of legal age.
- Despite full compliance with the Register of Deeds’ documentation requirements, issuance of the new certificate was still refused.
- Litigation Initiated by Felicidad Reyes-Talag
- On January 7, 1965, Felicidad Reyes-Talag petitioned the Court of First Instance of Laguna for an order directing the issuance of a new certificate of title in her favor for the 471-square-meter lot.
- The Acting Register of Deeds argued that:
- The petitioner should have pursued her case in the Land Registration Commission under Section 4, Republic Act No. 1151.
- The expropriation decision did not order the issuance of a new certificate nor did it adjudicate her ownership.
- The lower court, after considering the facts and the petitioner’s arguments, denied her petition on March 27, 1965.
- Appellate Proceedings and Final Developments
- Felicidad Reyes-Talag moved for reconsideration, citing an oversight in presenting the full notarial acknowledgment.
- Upon denial of her motion for reconsideration, Felicidad appealed the decision.
- In the appellate decision, the court highlighted:
- That the expropriation decision clearly excluded the 471-square-meter lot, thereby recognizing Felicidad Reyes-Talag as its owner.
- The sufficiency and validity of the deed of acknowledgment and the subsequent deed of confirmation.
- The absence of any opposition from the heirs regarding her claim.
- Her entitlement to a new certificate in view of justice and the specific set of circumstances.
Issues:
- Validity and Adequacy of Documents Presented
- Whether the public instrument in which Numeriano Reyes acknowledged the transfer to his daughter constitutes a sufficient mode of conveyance of real property.
- Whether the omission of the second page of the acknowledgment document, purportedly corrected by a later duly acknowledged exhibit, affects its validity.
- Application of Judicial and Statutory Provisions
- Whether the expropriation decision, which excluded certain parcels of land from government seizure, effectively served as adjudication of title in favor of Felicidad Reyes-Talag.
- Whether Section 44 of Act 496, as invoked by petitioner, is applicable in the issuance of new certificates or whether the petition should instead rely on Section 112 of Act 496.
- Procedural and Substantive Considerations
- Whether the petitioner, not being a party to the expropriation case, can rely on the decision as evidence of her title.
- Whether the cumulative documentary requirements imposed by the Register of Deeds were justifiably applied given the uncontested recognition of her ownership by all interested parties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)