Heirs of Gaudencio Blancaflor v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute stems from a judgment rendered by the Court of First Instance of Rizal in Civil Case No. 10270, ordering Gaudencio Blancaflor to pay Sarmiento Trading Corporation P9,994.05 plus interest and costs. Subsequently, a writ of execution was issued, leading to an auction sale where Lot No. 22, covered by Transfer Certificate of Title (TCT) No. 14749, belonging to Blancaflor, was sold to Sarmiento Trading Corporation. A final deed of sale was issued after the redemption period expired, and the Court of First Instance of Iloilo ordered the cancellation of Blancaflor's TCT and the issuance of a new one in favor of Sarmiento Trading Corporation. 2. Procedural History: Following the cancellation of the original title and the issuance of a new one to Sarmiento Trading Corporation, the property was transferred to Greater Manila Equipment Marketing Corporation (formerly Sarmiento Distributors Corporation). To facilitate the issuance of a new title in its name, Greater Manila Equipment Marketing Corporation filed a petition in the Regional Trial Court (RTC) of Iloilo, seeking an order for the heirs of Gaudencio Blancaflor to surrender the owner's duplicate copy of TCT No. 14749. The RTC granted the petition, ordering the surrender of the duplicate title and providing for its nullification and the issuance of a new title if not surrendered. The Heirs of Gaudencio Blancaflor appealed to the Court of Appeals, which affirmed the RTC's decision. The case is now before the Supreme Court on a petition for review on certiorari. 3. The Petition: The petitioners, the Heirs of Gaudencio Blancaflor, are seeking review of the Court of Appeals' decision under Rule 45 of the Revised Rules of Court. They argue that the causes of action to enforce the default judgment, the writ of execution, the final deed of sale, and the order for the issuance of a new title had prescribed under Article 1144 of the New Civil Code, as more than ten years had elapsed since the right of action accrued. They contend that the private respondent's petition to compel the surrender of the owner's duplicate certificate of title was filed belatedly, suggesting that prescription or laches had set in, and that the private respondent may have waited for Gaudencio Blancaflor's demise before pursuing the action.
Issue(s)
Whether the petition to compel the surrender of the owner's duplicate certificate of title is barred by prescription under Article 1144 of the New Civil Code. Whether the lack of personal notice to the registered owner regarding the registration of the levy and certificate of sale affects the validity of the involuntary conveyance.
Ruling
The petition is DENIED. The decision of the Court of Appeals, affirming the decision of the Regional Trial Court, is AFFIRMED in toto. Costs against petitioners.
Ratio Decidendi
On Issue 1: The Supreme Court held that the action had not prescribed because the judgment was already fully enforced through the levy and auction sale conducted in 1968. Under Philippine jurisprudence, specifically the ruling in Bautista v. Rule (85 Phil 39), title to property sold at an execution sale vests immediately in the purchaser, subject only to the judgment debtor's right to redeem within the statutory period. When Gaudencio Blancaflor failed to redeem the property within twelve months from the registration of the certificate of sale, he was completely divested of his rights to the lot. The subsequent petition filed by the respondent to compel the surrender of the owner's duplicate copy is not an 'action upon a judgment' contemplated by Article 1144 of the New Civil Code, but a summary proceeding under Section 107 of Presidential Decree No. 1529 to complete the registration process. Since the execution was already carried out, the lapse of 19 years did not extinguish the purchaser's absolute right to the property. Therefore, the defense of prescription is unavailing as the respondent was merely seeking the ministerial issuance of a new title certificate based on a finished execution. On Issue 2: The Court ruled that the registration of the notice of attachment and the certificate of sale constituted constructive notice to Blancaflor and his heirs. Pursuant to Section 52 of Presidential Decree No. 1529, any lien, attachment, or entry affecting registered land shall, once registered or entered in the office of the Registrar of Deeds, be constructive notice to all persons from the time of such entry. The Court clarified that in involuntary dealings, the registration of the instrument is the 'operative act' that binds the land, and the physical production of the owner's duplicate copy is not a prerequisite for the validity of the levy. Under Section 71 of Presidential Decree No. 1529, if the duplicate certificate is not presented at the time of registration of an involuntary lien, the Register of Deeds simply sends a notice to the owner to produce it; the failure of the owner to comply does not invalidate the registered lien. Consequently, Blancaflor was legally deemed notified of the levy and sale through the public records, and his heirs cannot claim lack of notice as a defense to the cancellation of the title.
Main Doctrine
A petition to compel surrender and/or cancellation of an owner's duplicate copy of a transfer certificate of title pursuant to Act No. 496 and P.D. No. 1529 is not barred by prescription where it is a consequence of an already enforced execution sale; inscription/registration of levy and certificate of sale constitutes constructive notice and the statutory cadastral/remedial procedures under Act No. 496 and P.D. No. 1529 are available to the purchaser to obtain a new certificate of title.