Case Summary (G.R. No. 98382)
Applicable Laws
The applicable laws invoked in the proceedings include Republic Act (RA) No. 26, which provides a special procedure for the reconstitution of lost or destroyed Torrens certificates, and Presidential Decree (PD) No. 1529, known as the Property Registration Decree.
Background of the Case
On April 16, 2004, Ungay Malobago Mines, Inc. filed a petition for the reconstitution of OCT No. 4784, asserting ownership of the mining patent tied to this certificate. The petition declared that the original certificate was lost during a diligent search and that the property is free from liens or encumbrances. However, the RTC dismissed the petition on July 17, 2006, determining that no factual or legal basis existed for the reconstitution and that the presented owner’s duplicate was not properly authenticated.
RTC Decision and Findings
The RTC determined that the owner's duplicate of OCT No. VH-4784, which was presented as the basis for reconstitution, lacked the necessary signature from the Register of Deeds, thereby lacking probative value. Furthermore, the RTC emphasized that Ungay Malobago Mines, Inc. was not the owner of the surface land, which had been titled to Rapu Rapu Minerals, Inc., thereby denying the petitioner’s entitlement to any certificate of title for the mining patent.
Court of Appeals Ruling
Following the dismissal by the RTC, Ungay Malobago Mines, Inc. appealed to the CA, which affirmed the lower court's decision on January 21, 2009. The CA ruled that, as a grantee of a mining patent, the petitioner did not possess ownership of the underlying land and consequently lacked the legal standing to file for reconstitution under RA No. 26. The CA held that the mining patent did not equate to an ownership interest in the land, thus negating the petitioner from claiming a right to reconstitute the lost certificate.
Legal Arguments Presented by the Petitioner
Petitioner raised two primary issues in its appeal to the Supreme Court. First, it argued that the CA erred by treating the request for reconstitution as one for ownership of the property itself, rather than as a reconstitution of evidence pertaining to the right to explore and extract minerals. Second, petitioner contended that the absence of the Register of Deeds' signature on the original certificate did not render the entire instrument void, and claimed that reconstitution should still be permissible.
Supreme Court Analysis
In reviewing the first issue, the Supreme Court upheld that the petitioner had indeed not established ownership of the land covered by the OCT, which was essential for any reconstitution claim. The Court reiterated established legal precedents that defined mining rights as separate from ownership of land, explaining that the right to mine does not include the
...continue readingCase Syllabus (G.R. No. 98382)
Case Background
- The case arose from a petition for review on certiorari regarding the Decision dated January 21, 2009 and the Resolution dated May 7, 2009 of the Court of Appeals (CA) in CA-G.R. CV No. 88210.
- On April 16, 2004, Ungay Malobago Mines, Inc. (petitioner) filed a verified petition with the Regional Trial Court (RTC) of Legaspi City for the reconstitution of Original Certificate of Title (OCT) No. 4784.
- The petition was based on the provisions of Republic Act (RA) 26 and Presidential Decree (PD) No. 1529.
- OCT No. 4784 was issued by then President Diosdado Macapagal on July 20, 1962, and registered in the Registry of Deeds of Albay on September 4, 1962.
- The petitioner alleged that the original copy of OCT No. 4784 could not be located despite diligent search, leading to the belief that it was permanently lost or destroyed.
Proceedings and Findings of the RTC
- The RTC conducted hearings and found no factual or legal basis for the reconstitution of the alleged lost certificate of title.
- Key findings included:
- The purported owner's duplicate of OCT No. VH-4784 was not signed by the Register of Deeds, Ramon Balana, questioning its validity.
- The absence of the Register of Deeds' signature rendered the duplicate a "scrap of paper" without any probative value.
- Petitioner was not the owner of the surface land, which was titled to Rapu Rapu Minerals, Inc., and thus lacked entitlement to the reconstitution of the certificate.
Decision of the Court of Appeals
- The CA affirmed the RTC's dismissal of the petition for reconstitution.
- The CA held that:
- Petitioner did not possess a legal personalit