G.R. No. 221978 - DMCI Project Developers, Inc. vs. Bernadas

Case Summary (G.R. No. 221978)

Labor Case and Annotation of Notice of Levy

Respondents obtained a favorable resolution in their labor case, resulting in a Notice of Levy annotated on TCT No. 25491 on March 15, 2006, indicating the execution of the NLRC decision affecting the title and ownership interests in the property. Subsequently, an auction sale was conducted on April 3, 2009, with respondents emerging as winning bidders.

Sale and Transfer to DMCI Project Developers

Following the auction, the Register of Deeds annotated a Certificate of Sale on the TCT, and on June 29, 2009, respondents executed a Deed of Sale and Release in favor of DMCI, ceding ownership of the subject lot to the latter after receiving monetary awards. Both parties then petitioned the Register of Deeds for the cancellation of the Notice of Levy and Certificate of Sale.

Subsequent Transfer and Motion to Nullify Documents

The subject lot was eventually transferred to Taguig Land Development Corporation and later merged with DMCI. Contrary to their prior actions, respondents moved before the NLRC to nullify the previously executed Deed of Sale and Release, alleging forgery and non-payment of monetary claims. One crucial contention was the falsity of signatures on the documents, and respondents claimed to have been deceived into signing.

Labor Arbiter’s Nullification Order and Grounds

The Labor Arbiter (LA) granted the motion to nullify the sale documents, cancelling the transfer and ordering the cancellation of Taguig Land's TCT No. 12619. The LA determined DMCI lacked standing to redeem the property under the NLRC Manual on Execution of Judgment, notably because DMCI was not a successor-in-interest or creditor with a lien. Attempts by DMCI to assert ownership via third-party claims were also dismissed for lack of evidence.

Appeals and Affirmations by NLRC and Court of Appeals

DMCI's appeal to the NLRC was denied, with the Commission affirming the LA’s nullification ruling. The Court of Appeals (CA) likewise rejected DMCI’s claim of ownership, upheld the registrability of respondents’ ownership under the labor case, and dismissed DMCI’s contention for lacking redemption rights.

Register of Deeds and Land Registration Authority (LRA) Consulta

Respondents sought to implement the LA’s nullification order through registration. The Register of Deeds referred the matter to the LRA via consultation (consulta) concerning:

Whether the NLRC had the authority to order title cancellation;
Whether the cancellation encompassed all interests, including those owners not party to the labor case.

The LRA resolved that the NLRC had jurisdiction to order cancellation and that the order covered the entire property. The LRA’s determination was affirmed despite DMCI’s motion for reconsideration.

Procedural History and Lapse of Appeal Period

DMCI filed a petition for review with the CA, challenging the LRA’s Resolution on grounds that the NLRC’s Entry of Judgment was prematurely issued and no writ of execution had been issued, supposedly invalidating the cancellation of its title. The CA denied the petition, emphasizing that subsequently issued Entry of Judgment rendered the matter final and executory.

Issue on Writ of Execution and Registrability of NLRC Order

The principal legal issue concerns whether the NLRC’s order for cancellation and entry of judgment are registrable and enforceable in the absence of a writ of execution. DMCI maintained that without such writ, no registration or implementation of the land disposition order should occur.

Legal Analysis: NLRC Jurisdiction and Execution Practices

The Supreme Court recognized that the NLRC Manual governs execution of its judgments. Regular courts lack jurisdiction over enforcement of labor tribunal decisions. Under the NLRC Manual, a writ of execution is an order directing enforcement but is only valid for 180 days, issued on a disposed final decision. While a writ is indispensable to enforce judgments, in this case, no writ of execution was yet issued because the Entry of Judgment only became final on May 16, 2012.

The LRA, in its consulta, did not waiver on the writ requirement but merely declared the order registrable. Registrability means the property may be registered under the judgment creditor's name, whereas actual registration is the Register of Deeds’ ministerial act after notice and compliance with requirements.

Distinction Between Registrability and Registration

The Court stressed that the Register of Deeds’ role is ministerial under Presidential Decree No. 1529 and that the officer must act upon the LRA's consulta unless appealed timely to the CA. The LRA’s consulta is not a registration per se, but a directive informing the Register of Deeds on the site’s registrability status based on judgment finality.

Compliance with Procedural Timelines and Effect of Judgment Finality

DMCI failed to timely appeal the LRA’s resolution within the required 15-day period after the denial of its motion for reconsideration, filing its petition 11 days late without any justification. This procedural default rendered the pages on cancellation final and executory. The Court cited its previous pronouncements that the perfection of appeal within reglementary periods is mandatory and jurisdictional; failure to do so affirms the finality and immutability of the judgment.

Doctrine of Immutability of Judgments and Scope of Review

The Court underscored the doctrine of immutability that judgments, once final, cannot be altered except under limited exceptions not present in this case. DMCI’s attempt to challenge the order’s execution on grounds related to ownership amounts to indirectly appealing the merits of the case, which is no longer permissible. The Court emphasized that finality cannot be circumvented by procedural collateral attacks.

Effect of Previous Court Decisions on Ownership Claims

The Court also recalled that DMCI’s ownership claims through merger and

Case Syllabus (G.R. No. 221978)

Background and Procedural History

The case concerns a 16,461-square-meter parcel of land in Taguig City covered by Transfer Certificate of Title (TCT) No. 25491, originally registered in the names of Honorato Lacsina and others.
Nelia Bernadas and co-respondents (Bernadas et al.) filed a labor case with the National Labor Relations Commission (NLRC) against Liberty Transport Corp. and/or Mr. and Mrs. Honorato Lacsina.
The NLRC ruled in favor of Bernadas et al., leading to a Notice of Levy annotated on TCT No. 25491 on March 15, 2006, to enforce payment.
On April 3, 2009, the subject lot was auctioned, and Bernadas et al. emerged as the winning bidder.
A Certificate of Sale was annotated on TCT No. 25491 on June 3, 2009, reflecting the sale for P1,915,800.
On June 29, 2009, Bernadas et al. executed a Deed of Sale and/or Certificate of Redemption of Real Property and a Release and Quitclaim in favor of DMCI Project Developers, Inc. (DMCI), transferring ownership of the lot to DMCI.
Subsequently, Bernadas et al. filed a motion before the NLRC to nullify these documents, alleging falsification and non-payment of their monetary claims.
The Land Registration Authority (LRA) was consulted due to conflicting registrations involving the property, and queries were raised about the authority of the NLRC and scope of the orders affecting the title.
DMCI contested Bernadas et al.'s claims and ownership assertions throughout the proceedings and filed various appeals before the Labor Arbiter (LA), NLRC, Court of Appeals (CA), and ultimately the Supreme Court.

Facts and Core Disputes

The initial labor case resulted in the selling of the subject lot in satisfaction of Bernadas et al.’s monetary claims.
Bernadas et al. then sold or redeemed the property to DMCI; however, Bernadas et al. later claimed spuriousness and fraud in the Deed of Sale and related documents.
The issue of ownership became contentious, leading to a legal battle assessing the validity and legality of the sale, redemption, and title transfers.
The NLRC found that DMCI lacked the legal personality to redeem the property under applicable rules since it was not the losing party or a creditor with lien rights.
The NLRC and CA ruled repeatedly in favor of Bernadas et al., nullifying the Deed of Sale and confirming the cancellation of the title under DMCI’s name.
DMCI pursued further remedies through the LRA, CA, and Supreme Court challenging the registrability of NLRC orders and the legal standing of Bernadas et al.’s claims.

Legal Issues

Whether the Court of Appeals gravely erred in affirming the LRA’s Resolution and Order allowing registration of the NLRC’s January 4, 2011 Order and subsequent Entry of Judgment affecting the property title.
Whether a writ of execution is indispensable before the NLRC’s order can be implemented or registered.
Whether the NLRC has authority to order cancellation of a TCT already issued.
The implications of procedural missteps by DMCI in filing appeals out of the reglementary periods.
The legal effect and binding nature of the LRA’s consulta and the principle of immutability of judgments regarding final orders.
The scope and limits of the Register of Deeds’ authority vis-à-vis the LRA and courts in registering or cancelling instruments and titles.

Ruling on the Writ of Execution Requirement

The Supreme Court confirmed the indispensability of a writ of execution for enforcement