Title
Soliman vs. Heirs of Ramon Tolentino
Case
G.R. No. 229164
Decision Date
Sep 2, 2019
Heirs contested reconstituted land title issued to Ramon, claiming co-ownership. SC upheld CA, ruling RTC erred in annulling title, violating judicial non-interference doctrine.
A

Case Digest (G.R. No. 229164)

Facts:

  • Ownership and Original Title
    • Spouses Doroteo Tolentino and Engracia Dela Cruz (spouses Tolentino) were the registered owners of a parcel of land measuring 200,944 square meters located in San Vicente, Pili, Camarines Sur, covered by Original Certificate of Title (OCT) No. RO 529 (263).
    • Their children were Ramon Tolentino (Ramon), Angeles Tolentino (Angeles), Rafael Tolentino (Rafael), Carmen T. Imperial (Carmen), and Mercedes T. Soliman (Mercedes).
  • Petition for Reconstitution of Title
    • The original OCT No. RO 529 (263) was lost or destroyed.
    • On August 25, 1977, Ramon filed a petition for the reconstitution of the lost certificate before the Court of First Instance (CFI), praying that the reconstituted title be issued in his name.
  • CFI Order and Issuance of Title
    • On January 20, 1978, the CFI issued an order granting the petition and ordered the issuance of a new title in Ramon’s name.
    • The order declared the original OCT lost and ordered the Register of Deeds to reconstitute and cancel the title and issue a new title in Ramon’s name.
    • On April 4, 1978, Transfer Certificate of Title (TCT) No. 3153 was issued in Ramon’s name.
  • Petitioners' Challenge
    • On August 29, 2012, petitioners—Mercedes, heirs of Angeles, and heirs of Rafael—filed a petition to annul the issuance of TCT No. 3153 and sought enforcement of an agreement of partition, reconveyance with damages, and interim injunctive reliefs.
    • They contended the property was co-owned by the heirs as heirs of the spouses Tolentino and that co-ownership was terminated through an Agreement of Partition executed after confrontation regarding the sole issuance of the title to Ramon.
    • Despite issuance in Ramon’s name, portions of the land were distributed under the Department of Agrarian Reform (DAR) to farmer-beneficiaries through Operation Land Transfer pursuant to PD No. 27; only Ramon received compensation. Petitioners’ possession of their portions remained undisturbed.
    • Subsequently, one of Ramon’s heirs repudiated the Agreement and claimed exclusive ownership.
  • Respondents' Answer and Defense
    • Only heirs Remigio Manchus (Remigio) and Antonio Tolentino (Antonio) filed an Answer asserting Ramon's exclusive ownership and possession, arguing that other siblings received other properties.
  • Proceedings and RTC Orders
    • The Regional Trial Court (RTC) of Pili, Camarines Sur issued an order on February 22, 2013, declaring the CFI order invalid as to issuance of title for want of jurisdiction. The motion for reconsideration by Remigio and Antonio was denied on April 15, 2013.
    • On June 10, 2013, petitioners filed a motion for summary judgment on the validity of the January 20, 1978 CFI Order.
    • On May 9, 2014, the RTC declared the CFI Order valid only in reconstituting the title but declared the issuance of TCT No. 3153 void for lack of jurisdiction.
  • Appeal to Court of Appeals (CA)
    • Antonio and Remigio appealed to the CA, challenging the RTC’s authority to annul or modify the CFI Order.
    • The CA consolidated the appeal and petitions and, on April 29, 2016, applied the doctrine of judicial stability (non-interference) to annul the RTC orders and dismiss the petition to annul TCT No. 3153, affirming the validity of the CFI Order.
    • Petitioners’ motion for reconsideration was denied by the CA on November 23, 2016.
  • Petition for Review on Certiorari
    • Petitioners filed the present petition questioning the CA’s application of the doctrine of non-interference in dismissing the annulment of title complaint.

Issues:

  • Whether the Court of Appeals erred in applying the doctrine of judicial stability (non-interference) in dismissing the petitioners’ complaint for annulment of Transfer Certificate of Title No. 3153.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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