Macabalo-Bravo v. Macabalo
REITERATIONFacts
The Antecedents: Elvira Macabalo-Bravo (Elvira) filed a petition for the issuance of a second owner's copy of Transfer Certificate of Title (T.C.T.) No. 232003, alleging that the owner's duplicate copy was mortgaged to her by Reynaldo dela Cruz and subsequently went missing from her files. Procedural History: The Regional Trial Court (RTC) granted Elvira's petition, ordering the issuance of a new owner's duplicate copy and declaring the original T.C.T. No. 232003 null and void. Juan Macabalo (Juan), Elvira's father, filed a petition for annulment of judgment with the Court of Appeals (CA), alleging that the RTC had no jurisdiction because the title was not lost but was in his possession. The CA reversed the RTC decision, vacating and setting aside the order and directing the annulment of the T.C.T. issued to Elvira, and consequently cancelling T.C.T. Nos. 322765 and 322766 issued to Elvira and Rolando Macabalo (Rolando), respectively. The Petition: Petitioners Elvira and Rolando Macabalo filed a petition for review on certiorari seeking the reversal of the CA Decision and Resolution, arguing that the RTC had jurisdiction and that the CA committed grave abuse of discretion.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack of jurisdiction in holding that the Regional Trial Court had no jurisdiction to issue the Order dated December 13, 1996. Whether the Court of Appeals committed abuse of discretion when it held that Juan Macabalo is in actual possession of the subject property and whether the Court of Appeals committed grave abuse of discretion amounting to lack of jurisdiction when it held that private respondent Juan is the real party-in-interest. Whether the Court of Appeals committed grave abuse of discretion amounting to lack of jurisdiction when it held that there was a trust created between Juan Macabalo and Elvira Macabalo-Bravo; and the effect of the void RTC Order and subsequent titles. Whether the Court of Appeals gravely abused its discretion amounting to lack of jurisdiction when herein petitioners were not given equal opportunity to testify before the court, thereby violating their right to due process. Whether the Court of Appeals abused its discretion amounting to lack of jurisdiction when it concluded that there was fraud in securing the signature of Reynaldo dela Cruz. Whether the remedy of Juan Macabalo should have been to file a civil case for reconveyance.
Ruling
The petition is DENIED. The Decision of the Court of Appeals dated June 6, 2000 and its Resolution dated July 21, 2000 are AFFIRMED.
Ratio Decidendi
On the jurisdiction of the RTC to issue the Order dated December 13, 1996: The Court held that the RTC, acting as a land registration court, has no jurisdiction to pass upon the question of actual ownership of the land covered by a lost owner's duplicate copy of a certificate of title. The purpose of a petition for the issuance of a new owner's duplicate copy is merely to have the instrument reproduced in its original form and condition, not to determine ownership. Crucially, if the owner's duplicate copy has not been lost but is in the possession of another person, the reconstituted title is void, and the court rendering the decision has not acquired jurisdiction. In this case, the petitioners themselves admitted that Juan Macabalo was in possession of the owner's duplicate copy of T.C.T. No. 232003, which means it was not lost. Therefore, the RTC Order dated December 13, 1996, directing the issuance of a new owner's duplicate copy and declaring the original null and void, was issued without jurisdiction and is consequently null and void. On the issue of whether Juan Macabalo is the real party-in-interest: The Court affirmed the CA's ruling that Juan Macabalo was the proper party-in-interest. The mere fact that he was in possession of the owner's duplicate copy of the certificate of title was deemed sufficient proof of his interest in the matter, particularly given his claim of ownership over the land by virtue of an implied trust. The CA correctly recognized that his claim of ownership, even if it needed to be threshed out in a separate suit, established his standing to question the validity of the RTC's order. On the effect of the void RTC Order and subsequent titles: The Court applied the ruling in Rexlon Realty Group, Inc. vs. Court of Appeals, which held that if the reconstituted title is void, then any subsequent titles issued based on that void title are also null and void. In this case, since the RTC Order was declared null and void for lack of jurisdiction, the subsequent subdivision of the property and the issuance of T.C.T. Nos. 322765 and 322766 in the names of Elvira and Rolando were also deemed null and void, as they were sourced from a void title. The Court noted that all necessary parties, including the transferees, were impleaded, justifying the resolution of the validity of the new titles within the same case. On the alleged violation of due process and denial of equal opportunity to testify: The Court found that the CA gravely erred and acted with grave abuse of discretion by referring the reception of evidence to a Division Clerk of Court instead of a Justice of the CA or a judge of an RTC, as provided by Section 6, Rule 47 of the Rules of Court. This procedural error rendered all proceedings held before the Division Clerk of Court invalid. Furthermore, the records did not clearly show that petitioners had commenced presenting evidence or had the opportunity to cross-examine witnesses, and more importantly, that Juan had made a formal offer of evidence as required by Sections 34 and 35, Rule 132 of the Rules of Court. The absence of a formal offer of evidence meant that no evidence for any of the parties had been validly admitted into the records. There is no ratio provided for the issue of fraud in securing the signature of Reynaldo dela Cruz. On the remedy of filing a civil case for reconveyance: The Court implicitly affirmed that a civil case for reconveyance would be the appropriate venue to thresh out issues of ownership, as it reiterated that the RTC, in a petition for the issuance of a second owner's copy, does not have jurisdiction to pass upon the issue of ownership. The CA's delving into ownership claims was therefore beyond its jurisdiction in the context of an annulment of judgment case concerning the issuance of a duplicate title.
Main Doctrine
A Regional Trial Court, acting as a land registration court, has no jurisdiction to order the issuance of a new owner's duplicate copy of a certificate of title if the original owner's duplicate copy has not been lost but is in the possession of another person. Consequently, any reconstituted title issued under such circumstances is void, and the RTC order granting the petition is likewise null and void.