Case Summary (G.R. No. 142913)
Applicable Law
The principle governing this case primarily stems from the 1987 Philippine Constitution, which dictates property ownership regulations and stipulations concerning foreign entities' eligibility to acquire land in the Philippines.
Factual Background
On December 27, 1967, a petition was filed by the heirs of Eleuterio Hernaez in the Court of First Instance of Bacolod City for the reconstitution of lost original certificates of title concerning various properties. The CFI granted the petition on April 6, 1968, leading to the issuance of reconstituted certificates of title. However, these were later canceled when the Hernaez heirs submitted a declaration of heirship, subsequently obtaining new Transfer Certificates of Title (TCT) in 1969.
Dispute and Initial Court Rulings
Upon learning of these developments, Salvador Serra Serra and his co-heirs filed an adverse claim and requested cancellation of the reconstituted titles. However, the trial court denied this request and granted possession of the properties to the Hernaez heirs, prompting Serra Serra to seek recourse through the Court of Appeals.
Court of Appeals and Supreme Court Involvement
The Court of Appeals intervened by initially issuing a preliminary injunction, which it later lifted. The petitioners subsequently pursued certiorari against this resolution, which led to a Supreme Court ruling on March 22, 1991, reinstating the injunction and directing the resumption of possession of the lands in question by the Serra Seras.
Subsequent Trial Court Decision
Following the Supreme Court's directive, the trial court heard the motion for cancellation of the titles, resulting in a November 25, 1998 judgment against the Serra Serra heirs. The trial court found for the Hernaez heirs, declaring the TCTs held by the Serra Seras null and void on the grounds that they were issued to foreigners, thus invalidating their claims based on citizenship issues.
Appeals and Final Rulings
The Serra Serra heirs, without seeking a reconsideration from the trial court, elevated the matter to the Court of Appeals which, on March 3, 2000, dismissed their petition for certiorari, emphasizing the absence of merit and procedural deficiencies, particularly the lack of a motion for reconsideration.
Supreme Court’s Final Determination
The Supreme Court affirmed the Court of Appeals' decision, delineating that the failure of the petitioners to file a motion for reconsideration constituted a significant procedural misstep. The Court reite
...continue readingCase Syllabus (G.R. No. 142913)
Case Background
- The case revolves around a petition for review on certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure, which challenges the March 3, 2000 decision of the Court of Appeals in CA-G.R. SP No. 52817, along with its resolution denying reconsideration on April 17, 2000.
- The original petition for reconstitution of lost original certificates of title was filed on December 27, 1967, by the heirs of Eleuterio Hernaez, namely Primitivo, Rogaciana, and Luisa Hernaez, concerning properties in Negros Occidental.
- The Court of First Instance (CFI) of Bacolod City granted the petition on April 6, 1968, leading to the issuance of reconstituted original certificates of title (OCTs), which were later replaced by Transfer Certificates of Title (TCTs) issued in the names of the Hernaez heirs after a declaration of heirship.
Dispute and Legal Proceedings
- Salvador Serra Serra, representing his co-heirs, registered an adverse claim against the TCTs and sought the cancellation of the reconstituted titles, asserting valid ownership and possession of the properties.
- The trial court initially denied the motion for cancellation and favored the Hernaez heirs, prompting Serra Serra to file a petition for certiorari with the Court of Appeals.
- A series of legal battles ensued, including a petition for certiorari, prohibition, and mandamus before the Supreme Court, which ultim