Case Digest (G.R. No. 150462)
Facts:
Top Management Programs Corporation v. Luis Fajardo and the Register of Deeds of Las Piñas City, G.R. No. 150462, June 15, 2011, Supreme Court Third Division, Villarama, Jr., J., writing for the Court.Petitioner Top Management Programs Corporation (petitioner) seeks to quiet title and recover damages against private respondent Luis Fajardo (private respondent) after competing Torrens titles were issued over the same parcel (Lot 1, Psu-204785, Mag-asawang Mangga/Almanza, Las Piñas). The controversy traces to parallel land registration proceedings in the 1960s: Emilio Gregorio (Gregorio) filed LRC Case No. N-5053 (application for Lots 1–4 of Psu-204785) and Jose T. Velasquez (Velasquez) filed LRC Case No. N-5416 (applications covering overlapping lots). The Court of First Instance (CFI) issued decisions in 1966, decrees of registration followed, and competing original certificates of title (OCTs) were issued in favor of the respective applicants.
After administrative reports by the Land Registration Authority (LRA) showing overlap, the CFI on November 23, 1966 set aside its own award to Gregorio in favor of Velasquez; Decree Nos. N-111862 to N-111865 (Dec. 6, 1966) and OCT Nos. 5677–5680 were issued in Velasquez’s name. Gregorio appealed; on July 30, 1971 the Court of Appeals (CA) reversed and ordered that the earlier March 9, 1966 order for issuance of a decree in LRC No. N-5053 in favor of Gregorio be given due course. Velasquez sought review before the Supreme Court; his petition was eventually denied by Resolution dated February 8, 1984, which became final and executory March 2, 1984.
Despite the appellate rulings and LRA reports warning of duplication, the RTC of Pasig (on March 21, 1986) declared null and void the Decree Nos. N-111862–N-111865 and directed cancellation of the OCTs in Velasquez’s name and issuance of new certificates to the Heirs of Gregorio. Thereafter, TCT Nos. 107727–107729 (April 29, 1986) and later TCT Nos. 4635/4636 (after partition) were issued in the name of Gregorio’s heirs. Separately, Gregorio had contracted with Tomas Trinidad and Luis Fajardo whereby they financed litigation in return for a share of the property; in Civil Case No. 35305 (RTC Pasig) Trinidad and Fajardo obtained a judgment (May 8, 1986) awarding them portions of the property. An Officer’s Deed of Conveyance dated August 15, 1989 led to issuance of TCT No. T-27380 (later T-34923) to Fajardo.
Petitioner acquired Lot 1-A from Gregorio’s heirs by a Deed of Absolute Sale (Nov. 29, 1988) and was issued TCT No. T-8129 (Feb. 20, 1989). Petitioner’s challenge to the CFI orders reinstating the August 14, 1989 order (seeking annulment for alleged extrinsic fraud) was dismissed by the CA and the Supreme Court on earlier petitions (CA-G.R. SP No. 26100; SC G.R. No. 102996, May 28, 1993). On February 10, 1994 petitioner filed Civil Case No. 94-564 in the RTC of Makati for quieting of title and damages against Fajardo; the tria...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in declaring TCT No. T-8129 defective on the basis that its origin traces to a void title, where petitioner alleges the entries are clerical errors reflecting issuance pursuant to a final determination in favor of Gregorio?
- Did the Court of Appeals err in upholding the validity of private respondent’s TCT No. T-27380, notwithstanding petitioner’s contention that its mother title (OCT No. 9587) was prematurely issued pending an appe...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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