Title
Supreme Court
Denila vs. Republic
Case
G.R. No. 206077
Decision Date
Jul 15, 2020
A dispute over land titles in Davao City, involving reconstitution claims by heirs and a buyer, was dismissed by the Supreme Court due to lack of jurisdiction and insufficient evidence of lost or destroyed titles.

Case Summary (G.R. No. 206077)

Historical Ownership and Lost Titles

Constancio S. Guzman and common-law wife Isabel Luna originally held multiple Torrens titles in Davao City registered in November 1925. Both died intestate during World War II, leaving no direct heirs. A corporation composed of Guzman’s collateral relatives, Heirs of Constancio Guzman, Inc. (HCGI), later sought judicial reconstitution of four of those titles, claiming they were lost or destroyed.

Initial Reconstitution Petitions and Dismissal

In 2001–2003, RTC Branch 14 required the Register of Deeds report on the subject titles. The report showed all four titles had been cancelled and transferred to third parties. In May 2003 the RTC dismissed HCGI’s petitions for lack of actual loss or destruction. HCGI’s direct appeal to the Supreme Court was denied in November 2003 for lack of jurisdiction and failure to prove title loss.

Heirs of Guzman, Inc. Ruling

The Supreme Court’s unsigned November 24, 2003 Resolution reaffirmed that the subject titles had been validly cancelled due to conveyances and were not lost or destroyed. It emphasized that reconstitution cannot be granted where titles remain registered in new owners’ names.

Amended Petition and RTC Proceedings

In June 2004 Denila filed an amended petition seeking reconstitution of seven original certificates of title (OCT 164, 219, 220, 301, 337, 514, 67), claiming certified LRA copies and LRA/Land Registration Office certifications of loss or mutilation. Notices were published, and trials ensued with testimony from LRA and RD officials.

RTC’s March 4, 2008 Reconstitution Decision

Presiding Judge Omelio granted Denila’s petition, finding that (a) RD cancellation entries were not authenticated, (b) LRA testimony proved original registration, and (c) the Republic offered no evidence on cancellation circumstances. The RTC ordered reconstitution and issuance of new Transfer Certificates of Title in Denila’s name.

Republic’s Petition for Relief and Judge’s Inhibition

After entry of judgment was prematurely declared final by the Clerk of Court, the Republic filed a Petition for Relief from Judgment under Rule 38. Judge Omelio voluntarily inhibited himself, directing re-raffle. The case was reassigned to another judge, then Judge Omelio re-assumed jurisdiction without raffle, denying the petition for relief as untimely.

Unauthorized Re-assumption and Summary Denial

Judge Omelio’s unilateral reversal of his own inhibition, lack of re-raffle, and summary denial without hearing violated due process and administrative guidelines. The Clerk’s premature certification of finality (based on receipt by the City Prosecutor, not the Solicitor General) compounded procedural irregularities.

Court of Appeals Certiorari Proceedings

The Republic filed a Rule 65 petition for certiorari in the Court of Appeals, alleging grave abuse of discretion in the RTC’s refusal to hear the relief petition, bias, and denial of due process. The CA issued TROs and injunctions to halt RTC orders, including reconstitution execution, fencing permits, and demolition writs.

CA Decision Granting Certiorari

On July 25, 2012, the CA held that the Republic timely filed its relief petition (computing from OSG’s receipt), that res judicata barred reconstitution of OCT 219, 337, 67, 164, that Judge Omelio abused discretion in summary denial, and that Denila failed mandatory RA 26 notice requirements. The CA voided the RTC’s decisions and orders.

Supreme Court Review Parameters

Review under Rule 45 is confined to questions of law and supervisory certiorari to correct jurisdictional errors or grave abuse of discretion. The SC must determine whether the CA correctly found the RTC deprived of jurisdiction by procedural and statutory violations.

RTC’s Jurisdictional Errors

Reconstitution proceedings require strict compliance with RA 26 jurisdictional prerequisites. The RTC granted reconstitution despite:
• Failure to notify actual occupants by registered mail or hand delivery (Sections 12–13, RA 26)
• Proceedings in rem bind the world through publication plus personal notice to interested parties
• Publication alone cannot cure lack of actual service

These lapses rendered the RTC decision void for want of jurisdiction.

Failure to Notify Actual Occupants

Denila’s petition claimed absence of structures and occupants, yet the issuance of demolition and fencing orders belied that claim. Several private respondents and the City of Davao, actual occupants or possessing governmental improvements, were never served notice. Their possessory and proper



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