Case Summary (G.R. No. L-1210)
Background Facts
In 1978, a document called the "Confirmation of Previous Sale" (CPS) was presented by Angel Abon, father of respondent Joey Abon, to the Register of Deeds, claiming a sale of the lot from the spouses Ramirez to him. Subsequently, a portion of the lot was segregated and titled separately as Transfer Certificate of Title No. T-50359. In June 2013, the petitioners discovered the CPS and initiated legal action to annul it, asserting that it was a result of forgery. This complaint was dismissed for lack of jurisdiction by the Regional Trial Court (RTC) of Nueva Vizcaya.
Procedural History
Following the dismissal, the petitioners pursued a certiorari petition before the Court of Appeals, which was ultimately denied for lack of merit. Concurrently, on July 5, 2013, Joey Abon filed a petition for reconstitution of the lost owner's duplicate of OCT No. 4480, claiming that the original has been lost. The RTC granted this petition on October 4, 2013, which subsequently became final and executory.
Arguments of the Petitioners
The petitioners argue the CPS does not specify the area sold and that the deeds evidence indicating ownership by the spouses Ramirez contradicts the claim of ownership made by Abon. They contend that the RTC lacked jurisdiction in granting the reconstitution because they, as the registered owners, were not notified of the proceedings, violating procedural safeguards designed to protect their interests.
Decision by the Court of Appeals
The Court of Appeals found no merit in the petitioners' claims and upheld the RTC's decision, resulting in the dismissal of their Petition for Annulment of Judgment. Consequently, the petitioners filed a motion for reconsideration, which was also denied.
Core Legal Issue
The principal legal issue before the Supreme Court is whether the Court of Appeals erred in its ruling by failing to acknowledge that the RTC did not acquire jurisdiction over the petition for reconstitution due to the lack of notice to the petitioners, who have a vested interest in the property as heirs to the registered owners.
Supreme Court Ruling
The Supreme Court determined that the petitioners' claim for annulment is valid. The Court emphasized that for a petition for reconstitution of a lost owner's duplicate to proceed, all interested parties—including the designated heirs of the registered owner—must be duly notified. The Court recognized that the petitioners, as heirs to the spouses Ramirez, retained their interest in the property and should have been afforded an opportunity to be heard.
Relevant Laws
The Court highlighted that Section 109 of Preside
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Case Information
- Case Citation: 857 Phil. 530
- Division: Second Division
- G.R. No.: 222916
- Decision Date: July 24, 2019
- Petitioners: Heirs of Spouses Gervacio A. Ramirez and Martina Carbonel, represented by Cesar S. Ramirez and Elmer R. Aduca
- Respondents: Joey Abon and the Register of Deeds of Nueva Vizcaya
- Judges: Caguioa, J. (with concurrence from Carpio, Perlas-Bernabe, J. Reyes, Jr., and Lazaro-Javier, JJ.)
Background of the Case
- The petitioners allege that Original Certificate of Title No. T-4480 (OCT) is registered in the names of the deceased spouses Gervacio A. Ramirez and Martina Carbonel and pertains to a 1,266-square meter lot (Lot 1748) in Barrio Sta. Lucia, Bagabag, Nueva Vizcaya.
- On May 30, 1978, Angel Abon, the father of respondent Joey Abon, requested a new owner's duplicate of the OCT based on a document termed "Confirmation of Previous Sale" (CPS), claiming to have purchased Lot 1748 from the spouses Ramirez.
- Using the new duplicate, Angel Abon managed to segregate a 135-square meter portion (Lot 1748-A) and obtain a Transfer Certificate of Title No. T-50359 (TCT) for that portion.
- In June 2013, the heirs of the spouses Ramirez received a copy of the CPS and subsequently filed a complaint for the annulment of the CPS, alleging forgery.
- The Regional Trial Court (RTC) of Nueva Vizcaya dismissed the complaint for lack of jurisdiction, prompting the heirs to file a certiorari petition with the Court of Appeals (CA), which was denied for lack of merit.
Petition for Reconstitution
- On July 5, 2013, respondent