Republic v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: This case concerns a petition for the judicial reconstitution of a destroyed Transfer Certificate of Title (TCT) No. 566, covering Lot No. 133-B. The original petition alleged that Moro Indulang and Maharajah Sacandal were the registered owners, with Mutalib Susukan, grandson of Moro Indulang, and other relatives possessing the lot. The owner's duplicate copy of the title was in Susukan's possession, and it was claimed the original was lost due to fire on February 8, 1974. Oppositors, heirs of Mora Dayang Sitti Fatima, contested this, asserting she was also a registered owner and that Susukan's duplicate copy was derived from a tampered original. 2. Procedural History: Mutalib Susukan filed a petition for reconstitution with the Regional Trial Court of Sulu. After publication and posting as required by Republic Act No. 26, the Solicitor General entered an appearance through the Provincial Fiscal. Oppositors filed their claim, leading to a compromise agreement between Susukan and the oppositors, which included Mora Dayang Sitti Fatima as a registered owner. The trial court approved this compromise and ordered the reconstitution of the title in the names of Maharajah Sacandal, Moro Indulang, and Mora Dayang Sitti Fatima. The government, through the Solicitor General, appealed this decision to the Intermediate Appellate Court (IAC). The IAC affirmed the trial court's decision in its entirety. The Republic of the Philippines, represented by the Solicitor General, then filed this petition for review on certiorari. 3. The Petition: The petitioner, the Republic of the Philippines, raises two main issues. First, it questions whether the Provincial Fiscal of Sulu's act of signing the compromise agreement without prior approval from the Solicitor General was binding on the government, given the Solicitor General's notice of appearance reserving approval for actions compromising government interests. Second, it challenges whether there was substantial evidence to support the IAC's affirmation of the trial court's decision, arguing that the owner's duplicate copy was unreliable and that insufficient evidence was presented to prove the original title's valid issuance and existence prior to its alleged destruction. The petitioner contends that the documents presented, including a Bureau of Lands certification and a prior court decision, were insufficient bases for reconstitution.
Issue(s)
Whether the Provincial Fiscal of Sulu's act of signing the compromise agreement without the Solicitor General's approval is binding upon the petition. Whether there is substantial evidence to support the decision granting the petition for reconstitution.
Ruling
The petition is DENIED. The decision of the Intermediate Appellate Court affirming the Regional Trial Court's order granting the petition for reconstitution is affirmed.
Ratio Decidendi
On the authority of the Provincial Fiscal: The Court held that the act of the Provincial Fiscal in signing the compromise agreement was in accordance with his duty to appear for and protect the interests of the government in court, as provided for in LRC Circular No. 35. This circular expressly grants provincial or city fiscals the authority to appear for and protect the interests of the government in reconstitution cases. The notice of appearance by the Solicitor General, while retaining supervision and control, did not negate this specific authority granted by the circular. Furthermore, the government's failure to oppose the petition despite due notice and its subsequent failure to file a motion to set aside the judgment after due notice indicated that no interest of the government was prejudiced by the fiscal's action. The Court emphasized that the fiscal's participation was within the scope of his mandated duties in such proceedings. On the sufficiency of evidence for reconstitution: The Court found that the allegation of insufficient evidence had no basis. Republic Act No. 26 provides for several sources for the reconstitution of certificates of title. While Susukan presented the owner's duplicate copy, the oppositors, to prove the ownership of Mora Dayang Sitti Fatima, presented a certification from the Bureau of Lands and a decision in a civil case. These documents, which established the ownership of all three registered owners, fall under Section 3(f) of Republic Act No. 26 as "any other document which, in the judgment of the court, is sufficient and proper basis for reconstituting the lost or destroyed certificate of title." The Court reiterated that if the evidence presented is sufficient and proper, and the petitioner is the registered owner, and the certificate was in force at the time of loss, the court has a mandatory duty to issue the order of reconstitution.
Main Doctrine
The act of a provincial fiscal in signing a compromise agreement in a petition for reconstitution of title, in representation of the government, is in accordance with his duty to appear for and protect the interests of the government in court, as provided for by LRC Circular No. 35, and does not require prior approval from the Solicitor General unless the government's interests are prejudiced. Furthermore, documents such as a certification from the Bureau of Lands and a court decision, which establish ownership, are considered sufficient bases for reconstituting a lost or destroyed certificate of title under Section 3(f) of Republic Act No. 26.