Case Summary (G.R. No. 198968)
Applicable Law and Procedural Framework
Constitutional framework applicable: 1987 Philippine Constitution. Procedural and substantive authorities applied in the case include Section 5, Rule 7 (certification against forum shopping) and Section 13, Rule 13 (proof of service) of the Rules of Court, Section 51 of PD 1529 as referenced by prior CA instructions, Article 476 and Article 1451 of the Civil Code (quieting of title; implied trust where legal title is placed in another’s name), and pertinent precedents cited by the courts below and by the Supreme Court.
Factual Background and Title Reconstitution
Lot No. 4012 was subdivided by court‑approved plan (1966) into 13 lots. The original TCT was lost in a 1959 fire and reconstituted as TCT No. (T‑13784) RT‑12612, listing various persons and shares, including the Spouses Deloy. Subsequent individual certificates of title were issued for the subdivided lots (including titles in the Province of Cavite’s name, later T‑19127 and T‑19128). Dionisio Deloy died in 1985; in 1989 Praxedes learned of titles issued in the Province’s name. The Deloy heirs filed an Annulment of Torrens Title suit, and the RTC (1998) and the CA (2001) found TCT Nos. T‑19127 and T‑19128 null and void and directed cancellation of the reconstituted TCT No. (T‑13784) RT‑12612 and re‑issuance in original form, subject to compliance with Section 51 of PD 1529 and other laws.
Post‑Annulment Transactions and Emerging Conflicts
Derivative titles had been issued over Lots 4012‑J, 4012‑K, and 4012‑L in the names of respondents’ predecessors and later in respondents’ names (TCT Nos. (T‑43159) T‑8554, (T‑25562) T‑22749, and (T‑29268) T‑69602). After the Annulment Case became final, the RD cancelled the reconstituted title and reissued in original form; later, following settlement of the Deloy estate, new titles in the name of Heirs of Spouses Deloy were issued (TCT No. 82597). Respondents complied with a request to surrender owner’s duplicate copies for annotation of the Deloy claim, and the Deloy heirs placed public notices asserting ownership. Respondents then filed separate petitions for quieting of title and removal of cloud, while Heirs of Spouses Deloy answered and asserted the reconstitution’s cancellation should invalidate derivative titles.
Lower Courts’ Dispositions
The RTC declared the Heirs of Spouses Deloy precluded from presenting evidence due to repeated failures to appear and ruled in favor of respondents, quieting respondents’ titles and ordering cancellation of the Deloy heirs’ subsequently issued title (TCT No. T‑82597), deleting annotations, and awarding attorney’s fees. The CA affirmed the RTC in a March 12, 2018 decision, upholding validity of respondents’ titles, accepting belated proof of authority for verifications, denying the Deloy heirs’ motion for new trial, and finding respondents had proven ownership in good faith for value.
Issues Presented to the Supreme Court
- Whether the CA erred in finding respondents substantially complied with the requirement of a certificate of non‑forum shopping.
- Whether the CA erred in upholding the RTC’s denial of petitioners’ motion for new trial (default consequences).
- Whether the CA erred in affirming the RTC’s grant of respondents’ petitions to quiet title.
Supreme Court’s Outcome and Relief
The Supreme Court granted the petition for review on certiorari, reversed and set aside the CA and RTC rulings, and dismissed the respondents’ quieting‑of‑title petitions. The Court held that respondents failed to prove valid acquisition of Lots 4012‑J, 4012‑K, and 4012‑L because their evidence was insufficient and the titles they relied upon were derived from a void reconstituted TCT.
Analysis — Certification Against Forum Shopping
The Court acknowledged respondents filed Verifications and Certifications Against Forum Shopping but questioned the authority of the signatories (Maurino and Angelita). The original special powers of attorney (SPAs) were not initially attached, but were later submitted during formal offer of evidence. The Court applied the doctrine that belated submission of proof of authority can amount to substantial compliance when the originals are subsequently produced, relying on existing jurisprudence recognizing substantial compliance in such circumstances. The Court cautioned against an overly literal application of the forum‑shopping certification rule that would frustrate orderly administration of justice.
Analysis — Motion for New Trial and Default
The RTC’s declaration that the Deloy heirs were precluded from presenting evidence was grounded on their repeated nonappearance. The Court reviewed the statutory grounds for a motion for new trial (fraud, accident, mistake, excusable negligence, or newly discovered evidence) and found the Deloy heirs failed to establish extrinsic or collateral fraud, accident, or excusable negligence. Although there were shortcomings in proof of service for certain RTC orders, the record showed a prior order setting hearing dates that had been received and not acted upon by the Deloy heirs; their counsel received notice of the RTC order declaring them in default. The Court applied the principle that notice to one of several counsel constitutes notice to all and concluded the Deloy heirs had no adequate explanation for failing to protect their interests; therefore, denial of the motion for new trial was proper.
Analysis — Quieting of Title: Standards and Application
An action to quiet title under Article 476 requires (1) legal or equitable title in the plaintiff and (2) proof that the instrument or record casting a cloud is actually invalid despite a prima facie appearance of validity. The Court emphasized that certificates of title derived from a reconstituted title issued through fraud, deceit, or other machination cannot constitute legitimate sources of ownership; however, an innocent purchaser in good faith for value may nonetheless acquire ownership if the purchaser’s acquisition is appropriately proven. The Annulment Case had declared certain province
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Procedural posture and relief sought
- Petition for Review on Certiorari under Rule 45 of the Rules of Court filed before the Supreme Court, assailing:
- Court of Appeals (CA) Decision dated March 12, 2018 in CA-G.R. CV No. 102176; and
- CA Resolution dated August 24, 2018 denying reconsideration.
- Underlying trials were Regional Trial Court (RTC), Branch 23, Trece Martires City — Joint Decision dated April 24, 2012 in Sp. Proc. Case Nos. TMSCA-005-08 and TMSCA-0008-07.
- Petitioners: Heirs of Dionisio Deloy and Praxedes Martonito Deloy (represented by Policarpio M. Deloy), the City Assessor of Trece Martires City, and the Register of Deeds for the City of Trece Martires.
- Respondents: Verna R. Basa-Joaquin (represented by Attorney-in-Fact Maurino J. Salazar), Heirs of Spouses Mariano Del Rosario and Macaria Guevarra, and Heirs of Maxima Guevarra (represented by Angelita G. Del Rosario-Zoleta).
- Relief sought in RTC by respondents: quieting of title or removal of cloud and damages with prayer for TRO and/or preliminary injunction over Lot Nos. 4012-J, 4012-K, and 4012-L.
Title, land description, and original registration
- Lot No. 4012: six-hectare parcel in Sta. Cruz de Malabon Estate, Trece Martires City, Cavite, originally covered by Transfer Certificate of Title (TCT) No. T-13784.
- Registered owners originally: siblings Dionisio Deloy (occupied five hectares) and Isabel Deloy (occupied one hectare).
- Dionisio sold portions of the land occupied by him; one buyer was Tomasa Figueroa who initiated a subdivision petition.
Approved subdivision and subdivision lots
- Subdivision plan approved by the Court of First Instance of Trece Martires City on February 15, 1966.
- Lot No. 4012 subdivided into 13 lots: 4012-A through 4012-M (listed sequentially as 4012-A, -B, -C, -D, -E, -F, -G, -H, -I, -J, -K, -L, -M).
Reconstitution of title and issuance of multiple titles
- Original TCT No. T-13784 reportedly lost in a fire (June 1959); the Register of Deeds (RD) of Cavite required reconstitution.
- Reconstituted title issued as TCT No. (T-13784) RT 12612 listing registered owners and shares:
- Isabel — 10,000 sq.m.;
- Spouses Daniel and Francisca Paredes — 5,000 sq.m.;
- Tomasa — 1,200 sq.m.;
- Province of Cavite — 9,122 sq.m.;
- Spouses Dionisio and Praxedes Deloy — 39,634 sq.m.
- Thereafter, the reconstituted TCT was cancelled and individual titles were issued for the subdivided lots (examples enumerated with TCT numbers and corresponding lots and areas, e.g., T-19127 for 4012-A in the name of Province of Cavite, T-19312 for 4012-J in the name of Dionisio, etc.).
Death, discovery of titles, and Annulment Case
- Dionisio Deloy died in 1985.
- In 1989, Praxedes discovered titles in the name of the Province of Cavite when searching for owner’s duplicate copies for Lot Nos. 4012-A and 4012-B.
- Praxedes and other heirs of Dionisio filed Civil Case No. TM-695 for Annulment of Torrens Title and Deed of Conveyance against the Province of Cavite and the RD.
- RTC Decision (February 5, 1998) granted relief for plaintiffs:
- Decreed deeds and conveyances presented by defendants null and void;
- Declared TCT Nos. T-19127 and T-19128 null and void and ordered their cancellation;
- Ordered RD to issue corresponding Torrens titles in the name of the late Dionisio Deloy or his heirs after payment of fees.
- CA Decision on appeal (August 23, 2001, CAA G.R. CV No. 61119) affirmed insofar as:
- Declared TCT Nos. T-19127 and T-19128 null and void and ordered cancellation thereof;
- Directed cancellation of the reconstituted TCT No. (T-13784) RT-12612 and re-issuance of a new one in its original form, "without prejudice to the annotation of subsequent dealings thereon";
- Ordered compliance with Section 51 of PD 1529 and other pertinent laws before cancellation/issuance of new titles.
Post-annulment RDs’ actions and impact on derivative titles
- After CA decision became final, the RD for Trece Martires City cancelled TCT No. (T-13784) RT 12612 and issued TCT No. (T-13784) RT-12612) T-66696 in lieu thereof; certificates issued in the name of the Province were cancelled.
- As a consequence, some titles originally issued in the names of third parties (including respondents’ predecessors-in-interest) were affected by the cancellation process and subsequent actions.
Respondents’ titles and claimed transactions
- Respondent Verna (through parents Spouses Gregorio and Iluminada Basa) claimed purchase of Lot No. 4012-J from Dionisio in 1967:
- Original TCT No. T-19312 was cancelled; substituted by TCT No. T-25563 in parents’ names; Verna purchased Lot No. 4012-J on May 4, 1970; TCT No. T-25563 cancelled and TCT No. T-43159 issued in her name; later renumbered as (T-43159) T-8554 when RD for Trece Martires City was created.
- Heirs of Maxima claimed purchase of Lot No. 4012-K from Dionisio on July 21, 1967 resulting in (T-25562) T-22749.
- Heirs of Spouses Del Rosario claimed purchase of Lot No. 4012-L from Dionisio on April 24, 1968 resulting in (T-29268) T-69602.
- Respondents later received letters (June 20, 2007) from RD requesting surrender of owner’s duplicate copies for annotation of the adverse claim of Heirs of Spouses Deloy; respondents complied and surrendered duplicates.
Heirs of Spouses Deloy’s post-annulment actions and notices
- Heirs of Spouses Deloy placed notices on Lots 4012-J, -K, and -L purporting to assert that the three parcels were the true property of Dionisio and Praxedes and citing CA Case No. CA-G.R. CV. No. 61119 (August 23, 2001).
- As a result of subsequent administrative actions and settlement of the Estate of Spouses Deloy, new titles were cancelled and then TCT No. 82597 was issued in the name of Heirs of Spouses Deloy on January 25, 2008.
RTC proceedings: petitions for quieting of title and procedural posture in trial court
- Respondents filed petitions for quieting of title or removal of cloud and damages with prayer for TRO/preliminary injunction before the RTC:
- Verna’s case docketed as Sp. Proc. Case No. TMSCA-005-08;
- Heirs of Spouses Del Rosario and Heirs of Maxima’s case docketed as Sp. Proc. Case No. TMSCA-0008-07.
- Heirs of Spouses Deloy filed Answers asserting among others:
- SPA executed by Verna was ineffectual;
- Cancellation of TCT No. (T-13784) RT 12612 should result in cancellation of all titles derived therefrom pursuant to the Annulment Case ruling;
- Titles of respondents are spurious and should be cancelled;
- Placement of sign/notices was an exercise of ownership rights.
- RTC declared Heirs of Spouses Deloy precluded from presenting evidence for repeated failure to appear in court (Order dated August 16, 2011).
RTC Decision — dispositive ruling (April 24, 2012)
- RTC ruled in favor of respondents, granting quieting of title and clearing clouds as follows:
- In TMSCA-005-08 (Verna): declared TCT No. (T-43159) T-8554 valid and subsisting; cancelled and deleted annotations at the back of that TCT; directed RD to cancel TCT No. T-82597 (in names of Heirs of Spouses Dionisio and Praxedes); directed City Assessor to cancel Tax Declaration No. 33-A; ordered private respondents to pay P50,000 attorney’s fees.
- In TMSCA-0008-07 (Heirs of Spouses Del Rosario and Heirs of Maxima): declared (T-29268) T-69602 and (T-25562) T-22749 valid and subsisting; cancelled and deleted annotations; directed RD to cancel TCT Nos. T-81202 and T-81203 (previously in the name of “DIONISIO DELOY married to PRAXEDES MARTONITO”); directed City Assessor to cancel Tax Declarations No. 1016-A and 1017-A; ordered private respondents to pay P50,000 attorney’s fees and costs of suit.
- RTC rationale:
- The RD’s implementation of the CA Annulment Case ruling caused problems because RD cancelled derivative titles without due regard for respondents’ existing, properly issued titles which were never declared missing.
- Found registration in respondents’ names to be in order and that respondents were the true owners by preponderance of evidence.
RTC post-decision events and appeals
- Heirs of Spouses Deloy filed Motion for New Trial; RTC denied it (Order dated July 11, 2012).
- Heirs of Spouses Deloy appealed to the CA (Notices of Appeal dated July 26 and July 30, 2012).
Court of Appeals ruling (March 12, 2018) and grounds of affirmation
- CA affirmed the RTC Joint Decision in CA-G.R. CV No. 102176 (Decision dated March 12, 2018).
- CA’s key holdings:
- SPA executed by Verna was sufficient because acknowledged before the Deputy Consul General; accepted SPA for Heirs of Spouses Del Rosario in favor of Angelita when filed with offer of evidence; defects in Verifications with Certification Against Forum Shopping deemed cured by subsequent submission of authorizations.
- Denial of motion for n