G.R. No. 155804 - Villanueva vs. Viloria

Case Digest (G.R. No. 155804)
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Facts:

Petition for a New Owner’s Duplicate Copy of TCT No. T-16156

On February 22, 2001, respondent Francisco Viloria, acting through his Attorney-in-Fact Samuel P. Vera Cruz, filed a verified petition before the RTC of Iba, Zambales, Branch 70, requesting the issuance of a new owner’s duplicate copy of TCT No. T-16156.
In his petition, respondent Viloria asserted:

He was the registered and absolute owner of the land covered by TCT No. T-16156.
The owner’s duplicate copy, kept in a wooden chest, was allegedly lost as the chest had been infested and partially destroyed by termites.
An Affidavit of Loss was executed and registered, affirming that the duplicate copy was irretrievably lost and not delivered to any third person or entity.

Trial Court Proceedings and Issuance of the New Title

After compliance with preliminary requirements, a trial ensued. On March 27, 2001, the RTC issued an Order:

The order directed the Register of Deeds of Zambales, upon payment of the corresponding fees, to issue another owner’s duplicate copy of TCT No. T-16156.
The lost owner’s duplicate copy was declared cancelled, null, and void, and the new duplicate was to be given like faith and credit as the original.

The RTC Order became final and executory on April 11, 2001, with the entry of judgment on June 5, 2001.
Following the order, on June 14, 2001, the Registry of Deeds of Zambales issued the new owner’s duplicate copy of the title, bearing SN No. 057212, in the name of respondent Viloria.

Subsequent Transactions Involving the Title

Respondent Viloria executed an Affidavit of Self-Adjudication of Sole Heir of his late wife, Cresencia P. Viloria, whose estate was covered by TCT No. T-16156. Notices of Self-Adjudication were published in the Philippine Recorder on January 14, 21, and 28, 2002.
On March 4, 2002, respondent Viloria sold Lot 227-C, covered by TCT No. T-16156, with an area of 585 square meters, to Ruben M. Marty for P350,000.
Consequently, the previously issued TCT was cancelled and, on April 25, 2002, a new title (TCT No. T-54657) was issued in the name of Ruben M. Marty by the Registry of Deeds of Zambales.

Petitioners’ Challenge and Alleged Irregularities

Petitioners Victorino F. Villanueva and Rosita M. Villanueva filed a petition for annulment of judgment under Rule 47 of the 1997 Revised Rules of Civil Procedure on May 10, 2002.
Their petition was premised on two primary grounds:

Lack of proper notice and information regarding the pendency of respondent Viloria’s petition.
Alleged extrinsic fraud and lack of jurisdiction, contending that the owner’s duplicate copy was not lost but was in the possession of petitioners who had purchased the property.

The petitioners supported their claim by submitting evidence that they possessed TCT No. T-16156 (with serial number 2136412), which was allegedly delivered to them by the late Cresencia P. Viloria, together with a copy of the sales contract and corresponding receipts of payment.

Court of Appeals (CA) Proceedings and Finality

On August 7, 2002, the CA dismissed the petition for annulment of judgment for lack of merit.
The CA held that:

The RTC had acted within its jurisdiction as the requirements under Section 109 of P.D. 1529 were met.
The alleged extrinsic fraud did not justify the annulment since failure to disclose matters that might defeat one’s claim during trial does not constitute extrinsic fraud.
Petitioners were not entitled to be notified regarding respondent Viloria’s petition because they were not the persons whose claim, right, or interest was annotated on the title.

A subsequent motion for reconsideration filed by the petitioners was denied on October 9, 2002, which led to the present petition for review under Rule 45.

Reference to Precedent Cases and Comparative Analysis

Petitioners cited the case of Rexlon Realty Group Inc. v. CA, wherein the Supreme Court annulled a trial court decision that reconstituted owner’s duplicate titles based on similar facts involving alleged loss and extrinsic fraud.
The cited precedent, along with related decisions (e.g., Strait Times, Inc. and Demetriou), emphasized that:

Misrepresentation, if occurring during trial, is not extrinsic fraud and does not preclude an adversary from rebutting evidence.
A trademark element of obtaining jurisdiction to reconstitute a title is the actual loss of the owner’s duplicate. If the duplicate is, in fact, possessed by another party, jurisdiction is lacking.

Issues:

Whether the Regional Trial Court (RTC) had jurisdiction to order the issuance of a new owner’s duplicate copy of TCT No. T-16156

Specifically, whether the requirement under Section 109 of P.D. 1529 was satisfied given the allegations that the duplicate was not really lost.

Whether the Court of Appeals correctly dismissed the petition for annulment of judgment

In particular, whether the grounds for lack of jurisdiction and extrinsic fraud were properly analyzed and decided in accordance with applicable precedents.

Whether the issuance of the new title by the Registry of Deeds, based on the RTC’s order, is void given the substantive evidence that the original duplicate was still in possession of petitioners

This issue involves the reconciliation of evidentiary findings and the proper application of jurisdictional prerequisites in reconstituting a title.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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