G.R. No. 250486 - Tagumpay Realty Corporation vs. Empire East Land Holdings, Inc.

On February 9, 2012, a condominium unit with parking (the subject property) covered by Condominium Certificate of Title (CCT) No. 5903-R, registered under Empire East Land Holdings, Inc. (Empire East), was sold at a public auction of tax delinquent properties.
Tagumpay Realty Corporation (Tagumpay Realty) emerged as the highest bidder and was issued a Certificate of Sale of Delinquent Property, which was annotated on CCT No. 5903-R.
After a lapse of one year without Empire East redeeming the property, title was consolidated in favor of Tagumpay Realty. Consequently, on May 8, 2013, a Deed of Conveyance was issued.

Tagumpay Realty became entitled to have a new CCT issued in its name; however, Empire East had not surrendered its duplicate owner's copy of the original CCT to the Registry of Deeds of San Juan City.
On November 6, 2013, Tagumpay Realty filed a Petition before the RTC, Branch 264, seeking:

The surrender of the owner’s duplicate of CCT No. 5903-R.
Alternatively, the cancellation of the existing CCT and the issuance of a new title in its name, citing Sections 75 and 107 of P.D. No. 1529.

The RTC Branch 264 initially granted the Petition on November 23, 2015, directing Empire East to surrender its duplicate copy and ordering appropriate actions from the Registrar of Deeds.
Subsequently, procedural complications arose:

The RTC referred the case for mediation on April 7, 2016, and suspended proceedings.
A Motion for Reconsideration was denied on June 21, 2016, due to non-joinder of issues at the time evidence was presented.
The hearing on the matter was set for May 23, 2018.
On April 26, 2018, the RTC directed Tagumpay Realty to justify why its Petition should not be dismissed for non-compliance with the second paragraph of Section 108 of P.D. No. 1529.

Dismissal in the Regional Trial Court and Subsequent Affirmation by the Court of Appeals

On July 30, 2018, the RTC dismissed Tagumpay Realty’s Petition for failure to comply with the venue requirement stated in Section 108 of P.D. No. 1529, ruling that land registration proceedings are in rem.
The RTC, emphasizing that registration proceedings attach to the land, held that all motions and petitions regarding registration must be filed in the original proceedings.
Tagumpay Realty’s Motion for Reconsideration was again denied on September 3, 2018.
The Court of Appeals (CA) affirmed the RTC’s dismissal in its decision dated April 11, 2019.
The CA further ruled that the issues raised affected the wisdom of the RTC’s decision rather than its jurisdiction; hence, Tagumpay Realty failed to establish grave abuse of discretion.
On October 28, 2019, the CA denied Tagumpay Realty’s subsequent Motion for Reconsideration, prompting the present Petition for Review on Certiorari.

Whether the CA erred in not finding grave abuse of discretion against the RTC for dismissing Tagumpay Realty’s Petition on the ground of non-compliance with the second paragraph of Section 108 of P.D. No. 1529.
Whether Tagumpay Realty’s remedy, which sought the surrender of the owner’s duplicate certificate of title, should be governed by Section 75 (in conjunction with Section 107) rather than Section 108 of P.D. No. 1529.
Whether the alleged failure to file the Petition in the original registration proceedings (as required by Section 108) constitutes a judicial error that justifies the issuance of certiorari.