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

Case Summary (G.R. No. 221978)

Key Dates and Procedural Milestones

Notice of levy annotated on TCT No. 25491: March 15, 2006. Public auction of the subject lot: April 3, 2009. Certificate of Sale annotated: June 3, 2009. Deed of Sale and Release/Quitclaim executed in favor of DMCI: June 29, 2009. Labor Arbiter order nullifying the Deed/Redemption and Quitclaim: January 4, 2011. NLRC Entry of Judgment: July 19, 2011; recalled March 22, 2012; subsequent Entry of Judgment declaring finality: May 16, 2012. RTC temporary restraining order and preliminary injunction in quieting action: April 19, 2012 and October 22, 2012 respectively. LRA consulta Resolution declaring order registrable: April 3, 2013; LRA denial of reconsideration: September 26, 2013. CA decision affirming LRA: June 5, 2015; CA denial of reconsideration: December 15, 2015. Supreme Court resolution: April 4, 2022. Applicable constitutional framework: the 1987 Philippine Constitution (decision date post-1990).

Facts

Bernadas et al. obtained a favorable labor award and caused a Notice of Levy to be annotated on TCT No. 25491. The property was auctioned and Bernadas et al. were recorded as the buyers. Bernadas et al. purportedly executed a Deed of Sale/Certificate of Redemption and a Release and Quitclaim transferring the subject lot to DMCI for P1,915,800.00. Taguig Land later acquired the lot and issued a new title (TCT No. 12619), and DMCI ultimately acquired the property by merger. Subsequently, Bernadas et al. moved before the NLRC to nullify the Deed/Certificate of Redemption and the Release/Quitclaim, alleging spurious/falsified documents and nonreceipt of the full monetary award. The Labor Arbiter granted the motion and ordered cancellation of TCT No. 12619 and issuance of a new title in favor of Bernadas et al. The NLRC affirmed, and entries of judgment were issued and later contested, producing a sequence of recall and reissuance of entries of judgment.

Procedural History and Intervening Proceedings

After the Labor Arbiter’s January 4, 2011 order and the NLRC’s affirmation, the Register of Deeds submitted a consulta to the LRA on whether the NLRC could order cancellation of a title and whether the order covered the entire lot. The LRA declared the NLRC order registrable. DMCI filed a motion for reconsideration with the LRA which was denied. DMCI then filed for judicial review with the Court of Appeals, which affirmed the LRA. DMCI sought relief in the Supreme Court by petition for review on certiorari.

Issues Presented

The central issue: whether the Court of Appeals gravely erred in affirming the LRA’s determination that the Labor Arbiter’s January 4, 2011 Order and the NLRC’s Entry of Judgment were registrable. Primary contentions by petitioner: the NLRC order should not be registered or implemented without a writ of execution; the CA overlooked a later Labor Arbiter order (June 19, 2015) denying a motion for execution and the pendency of DMCI’s quieting action in the RTC with injunctive relief; procedural irregularities in the issuance and recall/reissue of entries of judgment affected registrability.

Parties’ Contentions

Petitioner DMCI asserted that registration or implementation of the NLRC order requires an accompanying writ of execution; it relied also on its pending quieting of title action in the RTC and on the Labor Arbiter’s later denial of a motion for execution. Respondents Bernadas et al. maintained that the LRA and CA rulings faithfully applied law and jurisprudence recognizing the NLRC’s power to enforce and have registrable its final orders, and pointed to prior adjudications rejecting DMCI’s third-party claim of ownership.

Legal Framework Applied by the Court

NLRC Manual on Execution: defines writ of execution, prescribes conditions and time frames for issuance (writ valid for 180 days; writs issued after final disposition and with possession of case records including entry of judgment), and permits the NLRC or Labor Arbiter to issue writs motu proprio or upon motion within five years from finality.
NLRC Rules of Procedure (2011) and its provisions on motions for reconsideration and suppletory application of the Rules of Court.
P.D. No. 1529 (Property Registration Decree): duties of the Register of Deeds and the consulta procedure (Section 117) directing doubtful registration questions to the LRA Commissioner; the LRA’s resolution on consultas becomes conclusive and binding unless timely appealed.
Rule 43 of the Rules of Court and B.P. Blg. 129: appellate review and exclusive appellate jurisdiction of the Court of Appeals over quasi-judicial agencies such as the LRA; specific reglementary periods for appeals (15 days from notice; extensions limited).
Doctrine of immutability/finality of judgments as established in precedent: once final and executory, a judgment becomes immutable except in limited exceptions (clerical errors, nunc pro tunc, void judgments, or supervening circumstances making execution unjust).
Ministerial duty of the Register of Deeds to register instruments meeting requisites; the LRA’s role is to resolve registration doubts; registration is ministerial and gives notice but does not validate defective instruments.

Court’s Analysis on the Need for a Writ of Execution and Registrability

The Court recognized that a writ of execution is indispensable to enforce a final NLRC decision. However, the LRA’s consulta did not purport to dispense with the writ; it merely declared the NLRC’s January 4, 2011 Order and the accompanying Entry of Judgment registrable. The Court emphasized the distinction between a declaration of registrability and the ministerial act of registration. The LRA’s role is to state whether an order is registrable; the actual registration is performed by the Register of Deeds, who must follow the LRA resolution unless the resolution is timely and successfully appealed.

Court’s Analysis on Procedural Default and Finality

The Supreme Court stressed that the petitioner failed to comply with the reglementary period for appealing the LRA’s consulta resolution. After denial of reconsideration by the LRA (notice dated October 4, 2013), DMCI had 15 days to appeal but filed its CA petition on October 31, 2013—eleven days late—without offering any justification or seeking timely extension. The Court invoked the mandatory character of appellate time limits under P.D. No. 1529, R.A. No. 5434, and Rule 43, and cited jurisprudence that failure to comply renders the ruling final and executory and precludes further collateral attack. Consequently, the LRA resolution became conclusive and binding on the Register of Deeds.

Court’s Discussion on the Entries of Judgment and Immutability of Judgments

The Court addressed the sequence of NLRC entries of judgment, recalling and reissuing entries, and concluded that the May 16, 2012 Entry of Judgment rendered the January 4, 2011 Order final and executory. Given finality, the Court applied the doctrine of immutability of judgments and rejected petitioner’s attempt effectively to relitigate th

Case Syllabus (G.R. No. 221978)

Facts

Subject lot: parcel of land in Taguig City, area 16,461 square meters, covered by Transfer Certificate of Title (TCT) No. 25491 issued in the names of Honorato Lacsina married to Milagros Lacsina; Reynaldo Bonifacio Lacsina married to Evelyn Lacsina; and Renato G. Dionisio married to Corazon Platon Dionisio.
Labor case: Bernadas et al. (Nelia Bernadas, Noel Batanes, Eduardo Nonsol, Jose Balde, Elmor Mabatan, Lilio M. Rebueno) instituted a labor case against Liberty Transport Corp. and/or Mr. and Mrs. Honorato Lacsina; NLRC resolved in favor of Bernadas et al.
Notice of Levy: Annotation of Notice of Levy on TCT No. 25491 on March 15, 2006 (Entry No. 5371/25491) reflecting NLRC NCR Case No. 00-08-04508A-96 and the sheriff’s instrument dated March 15, 2006.
Auction and certificate of sale: Public auction conducted April 3, 2009; Bernadas et al. emerged as winning bidders. Register of Deeds annotated TCT No. 25491 on June 3, 2009 with Entry No. 3252 (Certificate of Sale in favor of Bernadas and co-claimants for P1,915,800), noting period of redemption.
Deed of Sale / Certificate of Redemption and Release: On June 29, 2009 Bernadas et al. executed a Deed of Sale and/or Certificate of Redemption of Real Property ceding the subject lot to DMCI for P1,915,800 (representing Bernadas’ monetary award) and executed a Release and Quitclaim discharging Honorato and Milagros Lacsina and DMCI from liabilities arising from the labor case.
Subsequent transfer and merger: Taguig Land Development Corporation acquired the subject lot and secured TCT No. 12619; Taguig Land later transferred the subject lot to DMCI by virtue of a merger.
Motion to nullify by Bernadas et al.: Bernadas et al. filed a Motion to Nullify the Deed of Sale / Certificate of Redemption and Release and Quitclaim with NLRC, alleging the documents were spurious/falsified (e.g., signatory Lidfiel Marikit purportedly died January 15, 1997; signatory Jerson Talam no longer part of judgment and unlocatable) and that Bernadas et al. were not paid the full monetary award (received only P100,000 from a surety company), alleging deception in obtaining signatures.
Sheriff’s Final Deed of Sale issued in favor of Bernadas et al. to consolidate ownership in their favor.
DMCI’s opposition: DMCI denied allegations, contended Evelyn Insilay-Rebueno (Evelyn) who filed the motion lacked authority because she already collected monetary claims (invoking Article 1919 on extinguishment of agency), and asserted full payment/satisfaction of judgment; argued LA should dismiss motion based on full payment.
Labor Arbiter (LA) Order January 4, 2011: LA Antonio R. Macam granted Bernadas et al.’s motion, nullified the Deed of Sale/Certificate of Redemption and the Release and Quitclaim, ordered cancellation of TCT No. 12619 issued to Taguig Land and issuance of a new TCT in favor of the complainants.
LA’s reasoning on redemption: LA held DMCI lacked personality to redeem the subject lot — not a redemptioner under Section 11, Rule VII of the NLRC Manual; DMCI not a successor-in-interest of owners of TCT No. 25491 and its third-party claim previously denied; DMCI failed to annotate TCT No. 25491 for 11 years and had insufficient evidence to support its claims.
NLRC proceedings: NLRC affirmed LA’s January 4, 2011 Order by Resolution dated May 27, 2011; an Entry of Judgment was issued July 19, 2011 declaring the May 27, 2011 Resolution final and executory.
Additional procedural steps: Bernadas et al., through Evelyn, sought implementation with Register of Deeds (August 25, 2011). The Register of Deeds elevated the question to the LRA by consulta (October 27, 2011) asking: (1) whether NLRC can order cancellation of a title already issued in Taguig Land’s name, and (2) whether the order includes cancellation of two-thirds shares of prior owners not parties to NLRC case.
DMCI’s parallel actions: DMCI filed a Complaint for quieting of title with RTC (November 4, 2011) seeking TRO/ preliminary relief; DMCI also filed motions and manifestations in NLRC contesting Entry of Judgment and procedural matters.
Subsequent NLRC actions and RTC injunctions: NLRC recalled the July 19, 2011 Entry of Judgment on March 22, 2012 for failure to resolve DMCI’s motion for reconsideration; NLRC later denied DMCI’s motion for reconsideration on April 4, 2012 for failure to file within 10-day reglementary period; RTC granted a temporary restraining order on April 19, 2012 enjoining Bernadas et al. from implementing the levy and certificate of sale; NLRC issued a subsequent Entry of Judgment on May 16, 2012; RTC issued a preliminary injunction on October 22, 2012 in favor of DMCI.
LRA consulta and resolution: LRA, in Consulta No. 5208, issued a Resolution dated April 3, 2013 ruling registrability of the January 4, 2011 NLRC Order and July 19, 2011 Entry of Judgment; LRA relied on Tanongon v. Samson and on prior CA decision (July 31, 2009) rejecting DMCI’s third-party claim; LRA concluded the January 4, 2011 Order pertains to the entire property and is registrable.
DMCI’s LRA motion for reconsideration (May 6, 2013) denied September 26, 2013 (Order), noting May 16, 2012 Entry of Judgment. Register of Deeds was thereby bound to act per consulta unless appealed.
Court of Appeals: DMCI filed a Petition for Review under Rule 43 with the Court of Appeals; CA denied the petition in a Decision dated June 5, 2015, affirming LRA Resolution April 3, 2013 and LRA Order September 26, 2013; CA held NLRC’s May 16, 2012 Entry of Judgment made issues moot/academic and invoked immutability of judgments. CA denied reconsideration (Resolution dated December 15, 2015).
Supreme Court: DMCI sought review by certiorari before the Supreme Court (G.R. No. 221978); SC resolved the Petition on Certiorari and affirmed the CA and LRA decisions by Decision dated April 4, 2022.

Procedural History (chronological highlights)

March 15, 2006 — Notice of Levy annotated on TCT No. 25491 (Entry No. 5371/25491).
April 3, 2009 — Auction sale of subject lot; Bernadas et al. winning bidders.
June 3, 2009 — Register of Deeds annotation of Certificate of Sale (Entry No. 3252).
June 29, 2009 — Deed of Sale/Certificate of Redemption and Release and Quitclaim executed in favor of DMCI.
October 18, 2007; July 31, 2009 — NLRC/CA proceedings relevant to DMCI third-party claims (prior CA Decision dated July 31, 2009 rejecting DMCI’s third-party claim became final and executory).
January 4, 2011 — LA Order nullifying Deed/Certificate of Redemption and Release and Quitclaim, ordering cancellation of TCT No. 12619 and issuance of new TCT in favor of complainants.
May 27, 2011 — NLRC Resolution affirming LA Order.
July 19, 2011 — Entry of Judgment declaring May 27, 2011 Resolution final and executory.
August 25, 2011 — Bernadas et al. requested Register of Deeds implement LA Order.
October 27, 2011 — Consulta elevated to LRA by Register of Deeds.
November 4, 2011 — DMCI filed Complaint for quieting of title in RTC (and sought TRO/PI).
March 22, 20