Case Summary (G.R. No. 233578)
Applicable Law
1987 Constitution (as the controlling constitutional framework for decisions rendered in 1990 or later), Presidential Decree No. 1529 (PD 1529) governing cadastral registration and the LRA’s duties under Section 39, and the Torrens system principles and jurisprudence governing land registration, presumption of regularity, and the finality/indefeasibility of registration decrees and titles.
Procedural Posture
This is a Rule 45 petition for review of a Court of Appeals decision that dismissed the Republic’s certiorari petition and affirmed the RTC’s directive that the LRA issue a registration decree and certificate of title in the name of respondents’ predecessors-in-interest for the entirety of Lot 459, Pasig Cadastre (LRC Case No. N-5999).
Trial Court Proceedings and Underlying Decree
Respondents filed an application for registration of Lot 459, docketed as LRC Case No. N-5999. They sought issuance of a decree of registration based on a final and executory RTC decision dated October 26, 1967, declaring Julian Sta. Ana and Mercedes Sta. Ana the owners of the subject parcel and ordering registration once the decision became final. The trial court, acting on an ex parte urgent motion, issued an Order for the Issuance of Decree (May 19, 1999) directing the Commissioner of the LRA to comply with PD 1529, Section 39, which requires preparation and issuance of a decree of registration and certificate of title after a final judgment directing registration.
LRA Reports and Concerns of Double Registration
The LRA submitted a Supplementary Report (October 11, 2000) informing the court that a portion of Lot 459 appeared to be already covered by a prior registration proceeding recorded as Cadastral Case No. 10, Cadastral Record No. 984. The LRA warned that issuing a new decree based on the 1967 decision could result in duplication of titles and undermine the Torrens system. The LRA recommended that applicants present an amended plan with technical descriptions segregating any portion already covered by title. The LRA also recounted multiple attempts to obtain the alleged cadastral decision, cadastral map, or equivalent highest lot number from the regional technical offices, but reported that no copy of the cadastral decision or adequate documentation was available in its records and that the regional office could not provide the necessary cadastral map or subdivision notation.
Trial Court’s Subsequent Orders and Parties’ Compliance Efforts
By order dated December 5, 2013, the RTC directed respondents to submit an amended plan and technical description segregating any portion already titled under Cadastral Case No. 10. Respondents filed a Manifestation and Urgent Motion for Reconsideration explaining that they could not produce the requested materials because the purported cadastral decision and related records were unavailable in government files and because the portion identified by the LRA was covered only by a tax declaration in the name of Ma. Jovita F. Fontanilla et al., whose claims the respondents contested. The Republic argued the motion was untimely and that respondents failed to comply. After considering the parties' submissions and the absence of any available records proving a prior title, the RTC issued an order (August 17, 2014) requiring the LRA to issue a title in the name of respondents’ predecessors consistent with the final and executory October 26, 1967 decision, concluding that issuance would not result in duplication of titles. The RTC denied the Republic’s motion for reconsideration (December 9, 2014).
Court of Appeals Decision
The Court of Appeals (assailed decision dated August 14, 2017) dismissed the Republic’s certiorari petition. The CA acknowledged the LRA’s report indicating a supposed prior cadastral decision but emphasized the LRA itself lacked a copy of that decision and could not identify the portion of Lot 459 allegedly covered. The CA gave weight to the RTC’s factual findings that no relevant cadastral decision or title could be located in the records of the LRA, DENR, or other government offices. The CA explained that the petitioner's attempt at fact-finding was improper via certiorari under Rule 65, and that factual determinations by the lower courts, supported by substantial evidence, are entitled to great weight and finality on appeal.
Present Petition and Arguments on Review
The Republic argued before the Supreme Court that a land registration court has no jurisdiction to order registration of a lot already decreed in the name of another through an earlier land registration case and relied on LRA reports asserting a portion of Lot 459 had been previously titled under Cadastral Case No. 10. The LRA had consistently recommended that respondents submit an amended plan segregating the allegedly titled portion, which the Republic asserted respondents failed to do. Respondents replied that they had earnestly tried to comply but could not locate any decision, decree, certificate of title, or technical description supporting the alleged prior registration and that they disputed the tax-declaration holders’ claim over the portion the LRA had identified.
Issue Presented
Whether the Court of Appeals committed reversible error in affirming the RTC’s directive to execute the final and executory October 26, 1967 decision by ordering the LRA to issue a registration decree and corresponding certificate of title in favor of respondents’ predecessors-in-interest covering the entire Lot 459.
Supreme Court Ruling and Holding
The Supreme Court affirmed the Court of Appeals decision and denied the Republic’s petition. The Court held that because there are no existing records—no text of any purported Cadastral Case No. 10 decision, no technical description of any portion allegedly covered, no identified parties in whose favor any prior title might have been issued—the LRA and the courts cannot ascertain any prior title that would conflict with the 1967 decision. The lone annotation in the LRA Record Book of Cadastral Lots (page 80) stating that a portion was covered by a certificate pursuant to Cadastral Case No. 10 is insufficient to identify its substance, extent, or beneficiaries. Given
...continue readingCase Syllabus (G.R. No. 233578)
The Case
- This Petition for Review assails the Decision dated August 14, 2017 of the Court of Appeals in CA-G.R. SP No. 139385 entitled "Republic of the Philippines v. Hon. Maria Gracia A. Cadiz-Casaclang in her capacity as Presiding Judge of the Regional Trial Court, Branch 155, Pasig City, and the Heirs of Julian Sta. Ana and Mercedes Sta. Ana."
- The Court of Appeals dismissed the Republic's petition for certiorari and affirmed the trial court’s directive for the Land Registration Authority (LRA) to issue a title on the subject lot in the name of respondents (the heirs of Julian Sta. Ana and Mercedes Sta. Ana).
- The Supreme Court, per Justice Lazaro-Javier, delivered the Decision under review.
Parties
- Petitioner: Republic of the Philippines, represented by the Office of the Solicitor General, including Solicitor General Jose Calida, Senior State Solicitor Alexander Salvador, and State Solicitor Jose Antonio Blanco in the present petition.
- Respondents: Heirs of Julian Sta. Ana and Mercedes Sta. Ana (successors-in-interest to Julian Sta. Ana and Mercedes Sta. Ana).
Subject Property and Original Decree
- Subject lot: Lot 459, Pasig Cadastre, Psc-14, docketed as LRC Case No. N-5999.
- A final and executory trial court Decision dated October 26, 1967 declared applicants Julian Sta. Ana and Mercedes Sta. Ana "the true and absolute owners of the parcel of land covered by Plan-AP 16200, in equal shares, pro-indivisio, and orders the registration thereof in (their) names," and ordered that "Once this decision becomes final, let an order for the issuance of Decree issue."
- Respondents rely on and seek execution of that 1967 Decision through LRC Case No. N-5999 as their legal basis for registration in their predecessors-in-interest’s names.
Proceedings Before the Regional Trial Court (LRC Case No. N-5999)
- Respondents filed an application for registration of Lot 459, Pasig Cadastre (LRC Case No. N-5999) which was raffled to RTC, Branch 155, Pasig City.
- On March 22, 1999, respondents filed an Urgent Ex Parte Motion for Issuance of a Decree based on the final and executory October 26, 1967 Decision.
- The trial court granted the ex parte motion and issued an Order for the Issuance of Decree dated May 19, 1999, directing compliance with Section 39 of Presidential Decree No. 1529 (PO 1529) to effectuate issuance of a registration decree and certificate of title.
LRA's Response and Supplementary Report
- The LRA, through Pelino Cortez, Director of the Department on Registration, submitted a Supplementary Report dated October 11, 2000, reporting that a portion of Lot 459 was already covered by a prior registration proceeding in Cadastral Case No. 10, Cadastral Record No. 984.
- The LRA warned that issuing a second registration decree based on the 1967 Decision would result in double registration and would contravene the Torrens system’s integrity, citing G.R. No. 63189 (Pedro E. San Jose vs. Hon. Eutropio Migrino, et al.).
- The Supplementary Report noted that the LRA’s records do not contain a copy of the alleged cadastral decision or the text of any prior decree, but that a notation appears on page 80 of the Record Book of Cadastral Lots, Book K, indicating "a portion of said lot is already covered by a certificate of title pursuant to the decision rendered in Cad. Case No. 10."
- The LRA recommended that applicants be ordered to present an amended plan of Lot 459 with technical descriptions, duly approved, segregating the titled portion included in Lot 459 per the alleged Cadastral Case No. 10.
- The LRA described efforts to ascertain details of the prior registration, including correspondence with the Regional Technical Director, National Capital Region, and the difficulties encountered:
- A January 4, 1989 letter requested information and a cadastral map print showing which portion was covered by patent title.
- A May 9, 1991 reply from the Regional Technical Director indicated they could not furnish the equivalent highest lot number nor the cadastral map because the cadastral survey was still in progress.
- A June 4, 1991 letter from the LRA furnished a Xerox copy of page 80 of the Record Book of Cadastral Lots and noted the Pasig cadastre survey dates.
- A June 16, 1992 reply from the Regional Technical Director stated the area sheet book for Lot 459 had no notation of previous subdivision and there was no record of subdivision.
Trial Court Orders and Related Pleadings
- By Order dated December 5, 2013, the trial court directed respondents to submit, within twenty (20) days from notice, an amended plan and technical description of Lot 459 segregating the already titled portion per Cadastral Case No. 10, Cadastral Record No. 984.
- Respondents filed a Manifestation with Urgent Motion for Reconsideration, arguing they could not comply because: (1) no copy of Cadastral Case No. 10 decision exists in agency files except a notation on page 80 of Book "K"; (2) the Regional Technical Director had no record of any public land application or patent on the subject lot; and (3) their efforts to comply were unavailing due to absence of records.
- The Republic opposed, contending the motion for reconsideration was filed out of time and that respondents failed to comply with the directive; the Republic argued issuance of title would result in overlapping titles.
- The LRA’s Supplemental Report dated October 1, 2013 was invoked by the Republic to assert the need for segregation to avoid duplication of titles.
Trial Court Ruling Granting Registration Decree (Order dated August 17, 2014)
- By Order dated August 17, 2014, the trial court granted respondents' Manifestation with Urgent Motion for Reconsideration and required the LRA to issue a title in the name of respondents' predecessors-in-interest over Lot 459 consistent with the final and executory October 26, 1967 Decision.
- The trial court’s reasoning included findings that:
- Respondents had seasonably filed the motion for reconsideration and had exhausted efforts to comply with the December 5, 2013 Order.
- The portion of Lot 459 that was to be segregated referred to land covered by Tax Declaration No. E-016-00025 issued to Ma. Jovita F. Fontanilla, et al., persons who had no title or document showing ownership and whose claim respondents contested.
- The RTC issued a certification that there was no record of a CFI Decision dated April 11, 1934 pertaining to Lot 459, and that various DENR and LRA divisions had no record of an application or patent covering a portion of Lot 459.
- The LRA had no record of the purported cadastral decision in Cadastral Case No. 10, Cadastral Record No. 984.
- Under these premises, issuance of a decree of registration pursuant to the 1967 Decision would not result in duplication of titles.
Motion for Reconsideration and Denial
- The Republic filed a Motion for Reconsideration (dated September 24, 2014), reiterating that respondents failed to comply with the December 5, 2013 Order and LRA instructions, and that issuance of title would create overlapping titles.
- Respondents filed a Comment/Opposition (dated November 19, 2014) arguing the issuance of a registration decree would not cause duplication because no prior title had actually been issued; DENR and other agencies certified no record of public land application or patent exists.
- By Order dated December 9, 2014, the trial court denied the Republic's motion for reconsideration.
Ruling of the Court of Appeals (Decision dated August 14, 2017)
- The Court of Appeals dismissed the Republic's petition for certiorari and affirmed the trial court’s order to issue a title in respondents' predecessors-in-interest’s names.
- The Court o