Strait Times, Inc. v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Private respondent Regino Peñalosa filed a petition for the issuance of new owner's duplicate certificates of title for TCT Nos. T-3767 and T-28301, alleging they were lost. The Regional Trial Court (RTC) of Tacloban City granted the petition, declaring the original titles void if recovered and ordering the Register of Deeds to issue new duplicates. Petitioner Strait Times, Inc. claims it purchased the property covered by TCT No. T-28301 from Conrado Callera, who had previously bought it from Peñalosa, and that its representative, Atty. Rafael Iriarte, has possessed the owner's duplicate of TCT No. T-28301 since August 14, 1984. 2. Procedural History: Following the RTC's order, which became final and executory, petitioner Strait Times, Inc. filed a petition to annul the order, alleging extrinsic fraud. The Court of Appeals dismissed this petition, denying reconsideration. The appellate court found that petitioner failed to prove extrinsic fraud and that the RTC had constructively notified the Register of Deeds. The Court of Appeals also questioned the timeline of the alleged sale and title delivery, noting discrepancies between the deed of sale date and the title issuance date. 3. The Petition: Petitioner Strait Times, Inc. seeks review of the Court of Appeals' decision via certiorari under Rule 45 of the Rules of Court. It argues that the RTC lacked jurisdiction to issue a new owner's duplicate certificate of title because the original was not lost but was in the possession of Atty. Iriarte, representing the petitioner. Petitioner contends that the RTC was misled by representations that the title was lost, constituting extrinsic fraud, and that the issuance of a new title under these circumstances is void. The core of the petition is that the trial court had no jurisdiction to issue the new duplicate title as the original was not lost, rendering the reconstituted title void.
Issue(s)
Whether there was extrinsic fraud on the part of private respondent in obtaining the new owner's duplicate of title. Whether the RTC had jurisdiction to issue the Order for the reconstitution of the owner's duplicate certificate of title.
Ruling
The petition is GRANTED. The assailed Decision and Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Judgment dated May 16, 1994, of the Regional Trial Court of Tacloban City, Branch 9, is ANNULLED, and the new owner's duplicate certificate of title issued in lieu of TCT T-28301 is declared VOID.
Ratio Decidendi
On the issue of extrinsic fraud: The Court ruled that there was no extrinsic fraud. The alleged fraud, which was the misrepresentation that the title was lost when it was in petitioner's possession, constituted intrinsic fraud, not extrinsic fraud. Extrinsic fraud prevents a party from having a trial or presenting their case, whereas intrinsic fraud pertains to issues raised and decided within the trial itself, such as the use of perjured testimony or forged documents. The Court noted that petitioner's failure to present its case was due to its own inaction in registering the Deed of Sale promptly, which would have allowed it to oppose the petition for reconstitution. On the issue of jurisdiction: The Court ruled that the RTC lacked jurisdiction to issue the Order for the reconstitution of the owner's duplicate certificate of title. It is judicially settled that a trial court does not acquire jurisdiction over a petition for the issuance of a new owner's duplicate certificate of title if the original is not lost but is in the possession of another person. In this case, it was undisputed that the allegedly lost owner's duplicate certificate of title was in the possession of Atty. Iriarte. Therefore, the reconstituted certificate of title is void, and the trial court acted in excess of its jurisdiction. The Court clarified that the issue of ownership must be litigated in appropriate proceedings and cannot be determined in an action for the issuance of a new owner's duplicate certificate of title or in proceedings to annul such certificate.
Main Doctrine
A trial court does not acquire jurisdiction over a petition for the issuance of a new owner's duplicate certificate of title if the original is not lost but is in the possession of another person. Consequently, such reconstituted certificate is void, and the issue of ownership must be litigated in appropriate proceedings.