Development Bank of the Philippines v. The Acting Register of Deeds of Nueva Ecija
REITERATIONFacts
1. The Antecedents: The Development Bank of the Philippines (DBP) acquired two parcels of land through an extrajudicial foreclosure sale. On June 13, 1980, DBP presented a sheriff's certificate of sale to the Register of Deeds of Nueva Ecija for registration. This transaction was entered as Entry No. 8191 in the Primary Entry Book, and the requisite fees were paid. However, annotation on the corresponding Transfer Certificates of Title (Nos. NT-149033 and NT-149034) could not be made because the original titles were missing from the Registry's files. 2. Procedural History: DBP subsequently initiated proceedings to reconstitute the missing titles, which was ordered by the Court of First Instance of Nueva Ecija on June 15, 1982. The titles were reconstituted on June 19, 1984. On June 25, 1984, DBP requested the annotation of the 1980 certificate of sale on the reconstituted titles, relying on the original Entry No. 8191. The Acting Register of Deeds, uncertain of the proper course of action, submitted a consulta to the Commissioner of Land Registration. The Commissioner ruled that Entry No. 8191 had become ineffective due to the prior unavailability of the titles and required a new entry with new fees. DBP appealed this resolution to the Court of Appeals, which then certified the case to the Supreme Court as it involved a pure question of law. 3. The Petition: DBP petitioned the Supreme Court, arguing that the Commissioner of Land Registration erred in declaring Entry No. 8191 ineffective. DBP contended that under Section 56 of Presidential Decree No. 1529, the entry in the primary book, coupled with payment of fees and the fact that the delay in annotation was not due to DBP's fault but to the missing titles, should be considered sufficient registration. DBP argued that requiring a new entry and fees would be unjust, especially since the original entry was made in good faith and all its obligations were met. The core of the petition is that the initial entry, despite the subsequent delay in annotation caused by circumstances beyond DBP's control, should retain its legal effect and allow for annotation on the reconstituted titles.
Issue(s)
Whether the sheriff's certificate of sale, entered in the Primary Entry Book in 1980, could be annotated on the reconstituted titles in 1984 using the original entry number. Whether the Acting Register of Deeds could validly annotate an entry made prior to his assumption of office.
Ruling
The Supreme Court set aside the resolution of the Acting Commissioner of Land Registration. It ordered the Register of Deeds of Nueva Ecija, or his successor, to annotate the certificate of sale in favor of DBP on the reconstituted titles, based on Entry No. 8191 dated June 13, 1980.
Ratio Decidendi
On the issue of annotating the certificate of sale using the old entry number: The Court held that Section 56 of Presidential Decree No. 1529 provides that instruments "shall be regarded as registered from the time so noted" in the primary entry book. This effect attaches to the mere making of the entry, without regard to the subsequent step of annotation on the certificate of title. The law contemplates that there may be intervals between the primary entry and the annotation, and the annotation, when made, shall bear the same date as the entry. The four-year delay in this case was not DBP's fault, as the original titles were missing from the Registry's safekeeping. DBP had complied with all its obligations, including payment of fees and presentation of the certificate of sale, which was registrable on its face. To require DBP to repeat the process and pay new fees would be unjust and inequitable, as the delay was attributable to the Register of Deeds. The Court reiterated the principle that in involuntary registrations, entry in the primary entry book is sufficient notice to all persons of the adverse claim, even without immediate annotation on the certificate of title. The Court clarified that current doctrine holds that entry alone produces the effect of registration for both voluntary and involuntary transactions, provided the registrant has complied with all requirements and nothing more remains to be done but a duty incumbent solely on the register of deeds. Therefore, the entry made in 1980 remained effective and could be annotated on the reconstituted titles. On the issue of the Register of Deeds annotating an entry made prior to his assumption of office: The Court found the respondent's qualms to be "more imagined than real." The act of annotating an entry is merely making a memorandum of an instrument and its entry, based on recorded details. This function is not exclusive to the incumbent at the time of entry and is not forbidden to successors. The annotation would simply give the memorandum the same date as the original entry, as commanded by law. Thus, the respondent Register of Deeds, or his successor, could validly perform this ministerial duty.
Main Doctrine
Entry in the primary entry book, even without immediate annotation on the certificate of title, produces the effect of registration for involuntary transactions, provided the registrant has complied with all requirements for entry and annotation, and the delay in annotation is not due to the registrant's fault.