Case Summary (G.R. No. 160684)
Procedural History and Trial Court Ruling
CLT sued Hi-Grade for annulment of TCTs 237450 and T-146941. The RTC found Hi-Grade’s older title (TCT No. 4211 lineage) tainted by patent defects and void, ordered cancellation of the two TCTs, restoration of CLT’s possession, and damages. A motion for new trial was denied.
Court of Appeals Decision and Resolution
On appeal, the CA granted the Republic’s intervention and took judicial notice of a Senate inquiry report on the Maysilo Estate. It reversed the RTC, upheld Hi-Grade’s titles as valid, dismissed CLT’s complaint, and ordered cancellation of CLT’s T-177013.
Issue I: Judicial Notice of Senate Report
CLT argued that taking judicial notice of an unauthenticated, hearsay Senate Report violated due process and separation of powers. The Court affirmed that under Rule 129, Section 1, a court must judicially notice official acts of the legislative department. The Senate Report’s findings are not binding; they merely supplement evidence subject to judicial scrutiny and do not supplant the court’s exclusive fact-finding role.
Issue II: Intervention by the Office of the Solicitor General
CLT contended the Republic lacked legal interest in private land disputes and that intervention was time-barred and unwarranted absent claims on the Assurance Fund. The Supreme Court agreed: intervention is permitted only before or during trial and only if the intervenor is indispensable. The Republic filed after judgment in the trial court, was neither indispensable nor asserting an actionable claim against the Assurance Fund in this proceeding, and thus should not have been allowed to intervene.
Issue III: Valid Registration Date of OCT No. 994
CLT relied on an OCT dated April 19, 1917; Hi-Grade relied on one dated May 3, 1917. Under Sections 41–42 of the Land Registration Act, the operative registration date is when the decree is transcribed in the Registry of Deeds—May 3, 1917. Hence, the genuine mother title is the May 3, 1917 document, and any title deriving from the April 19, 1917 document is void.
Issue IV: Validity of Derivative TCT No. 4211 and Successive Titles
CLT alleged multiple defects in TCT No. 4211 (e.g., language inconsistencies, missing survey references, altered tie points, forensic dating). The Court found CLT failed to prove nonconformity with 1918 registration procedures or to establish the absence or invalidity of the underlying subdivision plan. The NBI forensic report was inconclusive. CLT’s witnesses lacked demonstrated competence to opine on early-20th-century registration practices. Hi-Grade’s muniments of title and tax payments, coupled
Case Syllabus (G.R. No. 160684)
Procedural Context
- Petition for Review on Certiorari filed by CLT Realty Development Corporation (CLT) under Rule 45 of the Rules of Court, questioning the Court of Appeals’ Decision (18 June 2003) and Resolution (28 October 2003) in CA-G.R. CV No. 53770.
- CLT sought annulment of Transfer Certificates of Title (TCT) Nos. 237450 and T-146941, recovery of possession, and damages, after the RTC of Caloocan City (Branch 121) rendered judgment in its favor.
- Hi-Grade Feeds Corporation (Hi-Grade) appealed to the Court of Appeals, which reversed the RTC, upheld Hi-Grade’s titles, and ordered cancellation of CLT’s TCT No. T-177013.
Factual Background
- The disputed parcels form part of the historic Maysilo Estate (1,660.26 ha), originally covered by five mother titles (Original Certificates of Title, OCT), including OCT No. 994.
- Lot 26 of the Estate was successively sold, subdivided, consolidated, and partially expropriated by the Government, spawning multiple derivative titles and disputes.
- Hi-Grade’s chain of title traces from OCT No. 994 → TCT No. 4211 (Ruiz & Leuterio, 9 Sept. 1918) → TCT No. 5261 (Gonzalez) → TCT No. 35486 (Rufina Narciso Vda. de Gonzalez) → subdivision into TCTs 1368–1374 → expropriation into TCTs 12836–12842 → consolidation/subdivision into 77 lots under Psd-1828 → further subdivision (Psd-276839) resulting in Lot 17-B (Madulid, Sr.) and Lot 52 (Alvarez) → both sold to Hi-Grade → recorded as TCTs Nos. 237450 & T-146941.
- CLT acquired Lot 26 under TCT No. T-177013 by Deed of Absolute Sale with Real Estate Mortgage dated 10 December 1988 from Estelita I. Hipolito.
- CLT’s geodetic survey revealed an overlap between its titled area and Hi-Grade’s parcels, prompting Civil Case No. C-15463 for annulment, recovery, and damages.
Petitioner’s Contentions
- Hi-Grade’s titles are null and void for being fake and spurious, based on:
• Discrepancies in language (English on OCT No. 994 vs. Spanish on TCTs 4211, 5261, 35486).
• Omission of original survey dates (Sept.–Nov. 1911) and use of a conflicting date (22 December 1917).
• Absence of references to Lot 26 and subdivision plan numbers on TCTs 4211, 5261, 35486.
• Non-traceability of Plan Psd-21154 at th