G.R. No. 126673 - Strait Times, Inc. vs. Court of Appeals

The case arose from an action for the issuance of a new owner’s duplicate certificate of title filed by private respondent Regino PeAalosa before the RTC of Tacloban City, Branch 9.
The RTC, on May 16, 1994, rendered an Order declaring the allegedly lost titles (TCT Nos. T-3767 and T-28301) as null and void if they later reappeared, and directed the issuance of new owner’s duplicates in favor of Regino PeAalosa upon payment of the applicable fees.
After the RTC Order became final and executory on June 7, 1994, petitioner Strait Times, Inc., represented by Atty. Rafael M. Iriarte, filed a petition for its annulment alleging extrinsic fraud and other irregularities.

Private respondent’s application was based on the claim that his owner’s duplicates were lost.
However, it was brought to light that the original certificate (TCT No. T-28301) was in the possession of Atty. Iriarte, who had been holding it since August 14, 1984, when petitioner Strait Times, Inc. acquired the lot covered by the title from Conrado Callera.
Petitioner's submission emphasized that the lot had been in its possession even before the RTC proceedings, thereby questioning the very basis of the loss claim.

Petitioner alleged that the trial court was misled by a misrepresentation made by the attorney-in-fact of Regino PeAalosa (Emiliana Espinosa), who erroneously testified that the title was not pledged or delivered to any other party.
It was asserted that the misrepresentation was committed with a view to defraud the vendee, and that the affidavit of loss was perjured.
Petitioner contended that such extrinsic fraud should nullify the RTC Order and the issuance of the duplicate title.

Petitioner claimed that in 1984, a valid sale took place where the lot covered by TCT No. 28301 was transferred from Regino PeAalosa to Conrado Callera and eventually acquired by petitioner.
The defense argued that discrepancies existed in the chronology of the sale, registration, and issuance of the subdivided title, noting that the title was officially issued only in 1986 despite claims of an earlier possession.
Evidence such as multiple payment receipts and timing of tax payments were presented to support petitioner’s claim of prior rightful possession.

Whether extrinsic fraud was committed by private respondent in obtaining the new owner’s duplicate certificate of title.
Whether the alleged misrepresentations during trial amounted to extrinsic fraud justifying the annulment of the RTC decision.

Whether the RTC had jurisdiction to issue the order for a new owner’s duplicate certificate of title when the original was not actually lost but was in possession of petitioner’s counsel.
Whether the issuance of the duplicate certificate, in this case, is void because the original certificate remains extant.

Whether the ongoing action for the issuance or annulment of a duplicate certificate of title can satisfactorily determine the issue of ownership.
Whether the appropriate remedy for a title dispute should lie in separate, dedicated litigation rather than in proceedings for reconstitution of a title.