Case Summary (G.R. No. 133547)
Background of Motions for Reconsideration
Petitioners filed motions for reconsideration of this Court’s February 10, 2000 decision. They restated previously considered arguments, prompting this Court to reiterate that no new issues were raised and that prior findings were unassailable.
Irregular Issuance of PFINA Title
The Transfer Certificate of Title No. 186662 in favor of PFINA Properties, Inc. was declared irregular and void due to badges of fraud. The original owners (Heirs of Pael) had already divested themselves of any interest, rendering any subsequent transfer nugatory and fictitious.
Unregistered 1983 Assignment
PFINA’s claim rested on a purported deed of assignment dated January 25, 1983. Neither PFINA (then named PFINA Mining and Exploration, Inc.) nor the Pael heirs registered the deed or sought a new title for fifteen years. The transaction was dubious and incapable of conferring any legal rights since the Paels no longer owned the land.
Affirmation of Factual Findings
This Court affirmed the Court of Appeals’ factual findings as they were fully supported by the record. Absent any demonstration of factual error, those findings were treated as conclusive, and the legal conclusions derived therefrom were upheld as correct.
University of the Philippines’ Intervention
During the pendency of the motions for reconsideration, U.P. moved to intervene, asserting that the properties covered by TCT Nos. 52928 and 52929 overlap or encroach upon its title under TCT No. 9462. U.P. argued that any reconstitution or adjudication affecting those lands would cloud its campus title.
Legal Basis for Permissive Intervention
Relying on Rule 12 of the Rules of Court and precedents (Director of Lands v. CA; Mago v. CA), the Court recognized that procedural rules serve justice and should not bar parties with substantial interests. Although U.P.’s motion was late, denial would work an injustice and risk fraud or confusion over overlapping titles.
Competing Boundary Claims
Respondents Chin and Mallari contended their titles lie outside U.P.’s validly titled lands. The absence of clear boundary delineation in the voluminous records made it necessary to resolve the overlapping claims through further evidence.
Remand for Further Proceedings
To avoid multiplicity of suits and to resolve the dispute effici
Case Syllabus (G.R. No. 133547)
Procedural Posture and Parties
- Consolidation of two Supreme Court petitions: G.R. No. 133547 (Heirs of Antonio Pael et al.) and G.R. No. 133843 (Maria Destura)
- Petitioners moved for reconsideration of the Court’s February 10, 2000 Decision
- University of the Philippines filed a late motion to intervene during the reconsideration period
- Respondents: Court of Appeals, Judges Jorge H. Chin and Renato B. Mallari
Motions for Reconsideration
- Petitioners rehash previous arguments without raising new issues
- All arguments already considered and dismissed in the assailed Decision
- No factual or legal error pointed out to warrant reversal or modification
Irregular Title Issuance and Fraudulent Transfer
- Transfer Certificate of Title No. 186662 issued in favor of PFINA Properties, Inc. held irregular and illegal
- Reinstatement of respondents’ titles deemed proper, not collateral attack on PFINA’s title
- Deed of transfer from the Pael heirs to PFINA tainted with “badges of fraud and irregularities”
- Pael heirs had previously disposed of their rights; nothing remained to assign to PFINA
- Transfer characterized as fictitious and void
PFINA’s Claim and Motion to Intervene
- PFINA claimed acquisition by deed of assignment dated January 25, 1983
- Fifteen-year silence: deed unregistered, no new title issued, no steps taken to perfect ownership
- At acquisition, PFINA’s corporate name was PFINA Mining and Exploration, Inc., lacking lawful business purpose in urban real estate
- Courts of Appeals and Supreme Court found the 1983 transfer fabricated and legally ineffective