Cañero v. University of the Philippines
REITERATIONFacts
The Antecedents: Petitioner Domingo A. Cañero and his spouse filed a petition for the reconstitution of their Transfer Certificate of Title (TCT) No. 240042, covering a lot in Quezon City, alleging that the original copy was destroyed in a fire. They had declared the property for taxation purposes. Subsequently, Cañero learned that respondent University of the Philippines (UP) claimed title to the same lot and had a tax declaration in its name. Cañero's tax declaration also bore an annotation indicating a duplication with UP's property. This led Cañero to file an action to quiet title and cancel the annotation, asserting his ownership based on his reconstituted title and his father's prior possession, and arguing that UP had no valid claim as it failed to object during the reconstitution proceedings. Procedural History: The Regional Trial Court (RTC) initially granted Cañero's petition for reconstitution, issuing TCT No. RT-57204(240042). Later, after Cañero filed his action to quiet title, the RTC denied UP's motion to dismiss, finding that the action was not a collateral attack on UP's title, that prescription had not barred Cañero's claim due to his possession, and that a full trial was necessary. UP then filed a petition for certiorari with the Court of Appeals, assailing the RTC's orders. The Court of Appeals reversed the RTC's decision, dismissing Cañero's complaint. Cañero's subsequent motion for reconsideration was denied, leading him to file the present petition before the Supreme Court. The Petition: Petitioner Domingo A. Cañero filed a petition for certiorari under Rule 65 of the Revised Rules of Court, assailing the decision and resolution of the Court of Appeals. He argues that the appellate court erred in reversing the RTC's denial of UP's motion to dismiss and in nullifying his title without affording him a full trial. Cañero contends that he was deprived of his constitutional right to due process. The Supreme Court, however, found that the reconstitution proceedings were void due to lack of notice to UP, an adjoining property owner, as required by Republic Act No. 26. Furthermore, the Court affirmed that UP's title, being earlier registered, should prevail, and that Cañero's action to quiet title had prescribed. The Court also emphasized that the validity of UP's title had been settled in numerous prior cases, establishing res judicata.
Issue(s)
Whether the Court of Appeals erred in reversing and setting aside the orders of the Regional Trial Court which denied respondent's motion to dismiss, specifically concerning the validity of the reconstituted title, prescription, and possession. Whether the petitioner was deprived of his constitutional and statutory right to due process, considering the principles of res judicata and prior Supreme Court decisions regarding UP's title.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The petition for certiorari was dismissed, and treble costs were imposed against the petitioner.
Ratio Decidendi
On the issue of the validity of the reconstituted title and the action to quiet title, prescription, and possession: The Supreme Court held that the reconstituted title obtained by petitioner was void. Republic Act No. 26 provides a special procedure for the reconstitution of lost or destroyed Torrens certificates of title, not for existing ones. The RTC, Branch 82, never acquired jurisdiction over the reconstitution proceedings because it failed to notify respondent UP, an adjoining property owner, which is a mandatory jurisdictional requirement under Sections 12 and 13 of Republic Act No. 26. The Court emphasized that judicial reconstitution partakes of a land registration proceeding, requiring strict adherence to notice requirements. Since the reconstituted title is void, it cannot serve as a basis for an action to quiet title. The Court also noted that even if the lot had not been registered earlier, the reconstitution proceedings were void for lack of notice to adjoining owners. Furthermore, the Court pointed out that UP's title, TCT No. 9462, was registered much earlier than petitioner's reconstituted title, and established jurisprudence dictates that the earlier registered title prevails. The Supreme Court found that petitioner's action to quiet title had prescribed. The Court dismissed petitioner's claim of possession through "designated caretakers" as unsubstantiated and lacking any evidence in the records. In contrast, UP presented proof of its possession through buildings and structures it erected and maintained on the lot. The Court reiterated that UP had been in open, continuous, and uninterrupted possession of the lot since 1914, tracing its title from government ownership. On the issue of due process and res judicata: The Supreme Court held that petitioner was not deprived of due process. The Court of Appeals correctly nullified the reconstituted title on grounds of lack of jurisdiction and the binding effect of prior Supreme Court decisions. The Court stressed that the validity of UP's title to the Diliman Campus, including the subject lot, has been settled in numerous previous cases, such as Tiburcio, et al. vs. People's Homesite & Housing Corp. and Galvez vs. Tuason. These decisions established the principle of res judicata, making the issue of UP's ownership incontrovertible. The Court admonished courts and lawyers against entertaining spurious cases assailing UP's title, emphasizing that such actions are a waste of time and resources and undermine the rule of law. The Court also clarified that petitioner, as a subsequent litigant claiming the same property, is bound by these prior judgments, even if not a direct party to those cases.
Main Doctrine
A reconstituted title obtained without strict compliance with the notice requirements under Republic Act No. 26, particularly notice to adjoining property owners, is void for lack of jurisdiction. Such a void title cannot be the basis for an action to quiet title, and prior Supreme Court decisions affirming the validity of the respondent's title on the same property are binding on subsequent litigants under the principle of res judicata.