Case Summary (G.R. No. 200180)
Procedural History and Claims
On February 12, 2007, Marie Josephine S. CabaAez filed a petition with the Regional Trial Court (RTC) of Muntinlupa City to correct her name and marital status as they appeared on the titles of the aforementioned properties. She claimed that the titles erroneously reflected her as married to Benjamin H. CabaAez when they were merely in a common-law relationship. Her petition alleged that he was legally married to another woman, Leandra D. CabaAez, which was acknowledged in a previous compromise case that involved the properties. The RTC initially granted the petition on June 28, 2007, ordering the corrections to be made based on the evidence presented by the respondent.
Court of Appeals Decision
Petitioner Benjamin H. CabaAez later challenged the RTC decision via a petition for annulment, arguing that the court lacked jurisdiction as the necessary publication and service of summons were not conducted. On January 27, 2011, the Court of Appeals (CA) annulled the RTC's decision, primarily on the grounds of procedural deficiencies regarding publication and summons, violating the principles of due process.
Amended Decision by the Court of Appeals
In response to a motion for reconsideration by the respondent, the CA reversed its initial decision and reinstated the RTC’s ruling. The CA cited that the proceedings were governed by Presidential Decree No. 1529 (PD 1529), which facilitated the amendment of titles without necessarily requiring publication for jurisdiction. This new stance viewed the matter as falling under in rem proceedings where direct personal notice may not be required.
Legal Issues Raised by Petitioner
In presenting the case to the Supreme Court, Benjamin H. CabaAez raised various legal issues, questioning the CA’s procedure and its interpretation of applicable laws. The key points included whether the requirements for publication and service of summons were jurisdictional prerequisites, the nature of the proceeding under PD 1529, and whether the amendments in civil status constituted substantial changes needing full adversarial proceedings.
Supreme Court's Rationale and Conclusion
The Supreme Court found merit in the petitioner’s arguments but focused on the core aspects of jurisdiction and the nature of the claims involved. It emphasized that the amendments sought under Section 108 of PD 1529 pertained to non-controversial clerical errors. However, the existence of a serious objection and adverse claim from the petitioner indicated that the matter was indeed controversial and required a full trial rather than summary proceedings. Furthermore, the
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Case Overview
- The case involves a petition for review on certiorari filed by Benjamin H. CabaAez, challenging the Amended Decision and Resolution of the Court of Appeals dated August 29, 2011, and January 10, 2012, respectively.
- The controversy centers on two parcels of land in Alabang Hills, Muntinlupa, with areas of 739 and 421 square meters, covered by Transfer Certificates of Title Nos. 154626 and 154627.
- The registered owner on the titles is Marie Josephine S. CabaAez, who is claimed by the petitioner to be inaccurately listed as married to him.
Background of the Case
- On February 12, 2007, the respondent, Marie Josephine S. CabaAez, filed a petition with the Regional Trial Court (RTC) of Muntinlupa City for the correction of her name and marital status as registered owner of the properties.
- The petition was docketed as LRC Case No. 07-007 and alleged that:
- The petitioner is of legal age, single, and a resident of Alabang Hills.
- The titles were issued under her name but inaccurately indicated her as married to Benjamin H. CabaAez.
- Respondent claimed they were not legally married but were in a common-law relationship.
- Benjamin H. CabaAez is married to Leandra D. CabaAez, who had previously contested the property ownership.
- An Affidavit of Declaration Against Interest was presented, indicating Benjamin had no claim over the properties.
Proceedings in the RTC
- The RTC conducted ex parte hearings where the respondent presented evidence supporting her claims.
- On June 28, 2007, the RTC granted the petition