Case Summary (G.R. No. 233578)
Key Dates
October 26, 1967 – Trial court issues original registration decision in favor of Julian and Mercedes Sta. Ana.
March 22, 1999 – Respondents file ex parte motion for decree issuance.
May 19, 1999 – RTC Branch 155 issues Order directing LRA to prepare decree.
December 5, 2013 – RTC orders respondents to submit amended cadastral plan segregating a purported titled portion.
August 17, 2014 – RTC grants respondents’ motion, directing full registration.
August 14, 2017 – Court of Appeals affirms RTC.
March 15, 2021 – Supreme Court resolves Rule 45 petition.
Applicable Law
• 1987 Constitution (land‐registration cases post-1990)
• Presidential Decree No. 1529 (PD 1529), § 39 (procedure for issuance of decree and certificate)
• Rules of Court, Rule 65 (certiorari), Rule 45 (appeal)
• Torrens system principles (indefeasibility; presumption of regularity)
Procedural History
Respondents sought registration of Lot 459 via LRC Case No. N-5999. They relied on the final, executory 1967 RTC decision granting title to their predecessors. The RTC ordered the Land Registration Authority (LRA) to issue a registration decree. The LRA reported that a portion of Lot 459 was already registered under Cadastral Case No. 10 (Record No. 984), recommended an amended plan to segregate that portion, and warned against double titling. Respondents were unable to locate any decision, title or technical description under Cadastral Case No. 10 and challenged the supposed claim.
Trial Court Rulings
– May 19, 1999 Order: Directed LRA to comply with PD 1529 § 39 and issue decree.
– December 5, 2013 Order: Required respondents to file an amended plan segregating the allegedly titled portion.
– August 17, 2014 Order: Denied that any overlapping title existed (no records of Cadastral Case No. 10), found respondents had exhausted every effort, and directed LRA to register the entire lot per the 1967 decision.
– December 9, 2014 Order: Denied Republic’s motion for reconsideration, reaffirming full registration.
Court of Appeals’ Ruling
The CA dismissed the Republic’s certiorari petition. It held:
- LRA is the central repository under PD 1529; if it has no record of a cadastral decision, none exists.
- Respondents made earnest but unsuccessful efforts to comply with the RTC’s segregation directive.
- The Republic’s attempt to relitigate factual matters fell outside the scope of Rule 65.
- Substantial evidence supported the RTC’s findings that no prior valid registration existed.
Issue before the Supreme Court
Whether the CA committed reversible error in affirming the RTC’s directive to issue a registration decree for the entire Lot 459 in favor of respondents’ predecessors-in-interest.
Supreme Court Ruling
The Court affirmed. It reasoned
Case Syllabus (G.R. No. 233578)
Facts
- Respondents are the heirs of Julian Sta. Ana and Mercedes Sta. Ana who claim ownership of Lot 459, Pasig Cadastre, Psc-14.
- Their predecessors-in-interest secured a final and executory RTC decision dated October 26, 1967 declaring them “true and absolute owners” of Plan-AP 16200 (Lot 459) and ordering its registration.
- In 1999, respondents filed an Urgent Ex Parte Motion for Issuance of a Decree in LRC Case No. N-5999 to carry the 1967 decision into effect.
Proceedings before the Trial Court
- On May 19, 1999, the RTC granted the motion and directed the LRA Commissioner to issue the registration decree and certificate of title, pursuant to Section 39 of PD 1529.
- The LRA’s October 11, 2000 Supplementary Report revealed that a portion of Lot 459 was already covered by a prior cadastral registration (Cadastral Case No. 10, Record No. 984), warning that a second decree would duplicate titles.
- The LRA recommended that respondents submit an amended plan segregating the purportedly titled portion.
- A series of LRA letters to the DENR Regional Technical Director (1989–1992) failed to identify or furnish a cadastral map or clear technical description of the prior registration.
RTC Order of December 5, 2013
- The RTC ordered respondents to file, within twenty days, an amended plan and technical description segregating any portion covered by Cadastral Case No. 10.
- Respondents moved for reconsideration, explaining that no copy of Cadastral Case No. 10’s decision or map could be located and that records of any patent or subdivision were