G.R. No. 180069 - Philippine Commercial International Bank vs. Franco

The case is a petition for review on certiorari under Rule 45 of the Rules of Court filed by Teoville Homeowners Association, Inc. (petitioner).
It seeks to assail two earlier resolutions: one by the Court of Appeals dismissing Teoville’s petition and another dismissing its motion for reconsideration.

The controversy centers on a 711‑square meter lot (designated as Lot 98) in Teoville Subdivision, Parañaque City, originally owned by Villongco Realty Corporation.
Based on the approved original subdivision plans (1968), Lot 98 was designated as a saleable lot; however, prior to the project’s completion, the unsold lots – including Lot 98 – were transferred via a Deed of Sale and Assignment to REAM Development Corporation (REAM).
Improvements on the lot, such as a water system, equipment, and appurtenances, were included in that sale.

In 1985, following a severe water crisis in Teoville Subdivision II and a dispute regarding unpaid electricity bills, REAM donated a water distribution system (including a 30,000-gallon water tank and a 30-horsepower deep-well submersible pump) to Teoville through a Deed of Transfer and Donation dated 18 January 1985.
Edward L. Ferreira, at the time the Chairman of the Homeowners Association, accepted the donation.
The water pump and tank subsequently became inoperative and were dismantled.

On 16 April 1985, REAM, with the Land Registration Authority’s approval, subdivided Lot 98 into Lot 98‑A (300 square meters) and Lot 98‑B (411 square meters).
Lot 98‑A was sold to Edward L. Ferreira on 20 September 1985, which led to the cancellation of REAM’s original Transfer Certificate of Title and the issuance of a new TCT in Ferreira’s name.

On 04 August 1993, Teoville filed a Verified Complaint before the HLURB seeking:

Ferreira filed a Motion to Dismiss on the ground of lack of jurisdiction, which was disregarded by HLURB Arbiter Atty. Gerardo L. Dean who ruled him in default.
In his decision dated 10 July 1994, Arbiter Dean dismissed the complaint for lack of jurisdiction—holding that since the Registry of Deeds had already issued a title, the appropriate venue was the Regional Trial Court.
However, the Arbiter ordered REAM to complete its undertaking to donate Lot 98‑B to Teoville.
The HLURB Board of Commissioners, in its decision dated 21 May 1996, reversed the Arbiter’s ruling by declaring:

The re‑subdivision of Lot 98 as null and void;
The sale of Lot 98‑A to Ferreira as null and void; and
Ordered REAM to execute a deed of donation over Lot 98‑A in favor of Teoville, and to pay an administrative fine.

A motion for reconsideration by Ferreira and further interventions by Teoville, including an appeal to the Office of the President (OP).
The OP dismissed Teoville’s appeal in a decision dated 06 March 1998, affirming the HLURB Board of Commissioners, Special Division decisions dated 27 September 1996 and 15 January 1997.

Ultimately, the Court of Appeals dismissed Teoville’s subsequent petition on technical grounds (specifically on issues concerning the certification on non‑forum shopping and non‑attachment of duplicate original documents), first on 10 June 1998 and again after a motion for reconsideration was denied on 16 September 1999.

Teoville argued that its counsel, as the representative of the corporation, was authorized to sign the certification against forum shopping.
The petitioner also contended that the failure to attach duplicate original or certified true copies of pertinent pleadings, orders, and decisions should be overlooked in view of the substantive reproduction of the materials in its petition.
Respondents reiterated that the requirements under the Rules of Civil Procedure — particularly the need for the principal party to sign the certification and the submission of duplicate documents — are mandatory.
The Court noted the importance of observing procedural rules in order to ensure the orderly presentation and just resolution of the issues.

Whether the Rules of Court allow for a liberal interpretation or substantial compliance under Section 6 (c) and (d) of Rule 43.
Whether the certification against forum shopping, signed by counsel instead of by a duly authorized principal party, is acceptable.

Whether the failure to attach duplicate original/certified true copies of supporting pleadings, orders, decisions, and documents mandated under the Rules of Court constitutes a ground for dismissal.
Whether detailed reproduction or paraphrasing of the materials, as contained in the petition, is sufficient to satisfy the requirement.

Whether the appeal by certiorari from the OP decision is meritorious in light of the previous findings and administrative decisions.
Whether the argument regarding mere technical defects (non‑compliance with procedural matters, such as the certificate of non‑forum shopping) warrants a dismissal, despite any substantial factual or legal issues raised.

Whether an attempt to collaterally attack a Torrens Title registered and perfected after the reglementary period should be entertained.
How the doctrine of legal indefeasibility of Torrens Titles plays a role in restricting collateral attacks on title.