Case Summary (A.M. No. P-06-2196)
Facts of the Case
On May 16, 1997, the petitioners filed an application for the registration of the title to Lot No. 1524. This application was subsequently amended to claim the original Certificate of Title be issued to the late Jose R. De Luzuriaga, Sr., based on Decree No. 22752. The Regional Trial Court (RTC) ultimately granted this application, confirming the title of the late De Luzuriaga to the lot, a decision which became final as the respondent opted not to file an appeal.
Subsequent Legal Actions
In September 1999, Dr. Antonio A. Lizares, Co. Inc. (also referred to as DAALCO), initiated a quieting of title action against the petitioners, asserting that they were the lawful owners of Lot No. 1524, based on a prior Transfer Certificate of Title. Following this, the Republic filed a petition for relief from judgment, seeking to vacate the previous decision based on several grounds including improper representation by the petitioners and potential double titling of the same lot.
RTC Rulings
The RTC denied the government's petition for relief due to insufficient procedural grounds, later determining that jurisdictional issues were not substantive enough to reverse the earlier decision. The Republic's subsequent motion for reconsideration was also denied.
CA Ruling
The Court of Appeals granted the Republic's petition for certiorari, finding that the RTC had gravely abused its discretion in denying the relief from judgment. It remanded the case to the RTC for further proceedings concerning the possibility of double titling, citing that this would need examination in light of DAALCO's claims.
Issues Presented
The petitioners raised several issues including alleged errors by the appellate court in granting the certiorari without finding grave abuse of discretion, violations of the principle of judicial stability, res judicata, and concerns about procedural propriety regarding the Republic’s failure to file a timely appeal.
Disposition of the Supreme Court
The Supreme Court, affirming the CA's decision, found that the CA acted within its jurisdiction in granting the petition, emphasizing the necessity for a thorough examination of potential double titling concerning Lot No. 1524. It justified the procedural relaxation for the Republic to present its case, arguing that substantial justice must prevail over rigid adherence to procedural rules.
Double Titling Concerns
The Court highlighted that a prima facie case of potential double titling existed given that another original title had already been issued for the same l
...continue readingCase Syllabus (A.M. No. P-06-2196)
Background of the Case
- This case involves two petitions filed under Rule 45 by the heirs of the late Jose De Luzuriaga against the Republic of the Philippines, represented by the Office of the Solicitor General (OSG).
- The petitions contest the November 26, 2004 Decision and May 25, 2005 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 75321, which reversed the orders of the Regional Trial Court (RTC) in Cadastral Case No. 97-583, Bacolod City.
Facts of the Case
- The subject of the controversy is Lot No. 1524, located in Bacolod, with an area of 268,772 square meters.
- On May 16, 1997, the petitioners filed an application for registration of title for Lot No. 1524 before the RTC, including a survey plan and technical description approved by the Department of Environment and Natural Resources (DENR).
- The application was amended on May 12, 1998, to order the registration of the lot in the name of the late Jose R. De Luzuriaga, Sr. pursuant to Decree No. 22752.
RTC Decision and Subsequent Actions
- The RTC issued a decision on May 24, 1999, confirming the title of the late De Luzuriaga over Lot No. 1524, leading to the issuance of Original Certificate of Title (OCT) No. RO-58.
- Dr. Antonio A. Lizares, Co., Inc. (DAALCO) filed a complaint against the petitioners for quieting of title, cl