Opriasa v. City Government of Quezon City
REITERATIONFacts
1. The Antecedents: Respondent City Government of Quezon City filed a petition to reconstitute Transfer Certificate of Title No. 23110, alleging that the original title was destroyed in a fire. The City Government claimed ownership of the property based on a deed of donation from J.M. Tuason. The petition for reconstitution was filed under Section 3(c) of Republic Act No. 26, utilizing a certified true copy of the title as a basis. 2. Procedural History: The Regional Trial Court (RTC) of Quezon City granted the City Government's petition for reconstitution on March 13, 1991, despite a query from the Land Registration Authority regarding the clarity of the technical description. This order became final and a reconstituted title, TCT No. RT-28565, was issued. Petitioners, claiming to be occupants of a portion of the property, learned of the reconstituted title in 1996 and subsequently filed a petition for annulment of the RTC's order with the Court of Appeals (CA). The CA dismissed their petition, finding no extrinsic fraud and that the action was filed out of time. The CA's decision was later affirmed upon denial of the motion for reconsideration. 3. The Petition: Petitioners seek review of the CA's decision, arguing that the RTC lacked jurisdiction due to the failure to provide actual notice to them as occupants, as required by Sections 12 and 13 of RA 26, and that extrinsic fraud was committed. They also contend the RTC acted without jurisdiction by proceeding without the LRA report and by ordering the title reconstituted in the name of the Quezon City Government, despite discrepancies in the property's area. Petitioners assert that their petition for annulment was timely filed within the four-year period from discovery of the alleged fraud.
Issue(s)
Whether the trial court acquired jurisdiction over the petition for reconstitution despite lack of actual notice to petitioners as occupants or persons in possession of the property; Whether there was extrinsic fraud; Whether the period to file a petition for annulment of judgment had already prescribed; Whether the trial court acted without jurisdiction when it issued the 13 March 1991 Order without waiting for the LRA report; Whether the trial court acted without or in excess of its jurisdiction when (a) it ordered the reconstitution of the title "in the name of the Quezon City Government" and (b) it ordered the reconstitution of the title although there was a discrepancy in the area of the property as indicated in the 13 March 1991 Order and in the notice of hearing.
Ruling
The petition is denied. The Decision dated 31 July 2000 and the Resolution dated 18 July 2001 of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of jurisdiction and notice to occupants: The Court held that for a trial court to acquire jurisdiction over a petition for reconstitution, occupants of the property must be notified. However, in this case, the petitioners' prior filing of a civil case for recovery of possession against the respondent, filed before the reconstitution petition, indicated they were no longer in possession of the property when the reconstitution petition was filed. Therefore, they were not entitled to notice as occupants or possessors, and their claim of lack of notice as a basis for lack of jurisdiction was dismissed. Consequently, their claim of extrinsic fraud based on lack of notice also failed. On the issue of extrinsic fraud: The Court found no extrinsic fraud. Extrinsic fraud requires that the fraudulent act prevented a party from having his day in court. Since the petitioners were found not to be in possession at the time of the reconstitution proceedings, they were not entitled to notice, and thus, were not deprived of their day in court by any fraudulent act. Furthermore, the Court of Appeals found that the petitioners had knowledge of the proceedings, citing petitioner Opriasa's status as a barangay official and awareness of development programs. On the issue of prescription: The Court affirmed the Court of Appeals' finding that even if extrinsic fraud existed, the petition for annulment of judgment was filed beyond the four-year prescriptive period provided by the Rules of Civil Procedure. The petitioners claimed discovery of the fraud in 1996, but the appellate court found their claim of late discovery not credible, especially considering their prior involvement in related land disputes and Opriasa's position. On the issue of the trial court acting without jurisdiction by not waiting for the LRA report: The Court reiterated its ruling in Puzon v. Sta. Lucia Realty & Development Inc. that non-compliance with LRC Circular No. 35, specifically the failure to await the LRA report, does not divest the trial court of jurisdiction. The circular does not make it mandatory for the court to wait indefinitely for such reports; it may validly issue an order of reconstitution if no report is forthcoming by the initial hearing date. On the issue of the trial court acting without or in excess of jurisdiction regarding the name of the title and property area: The Court clarified that the trial court's order to reconstitute the title was in favor of the Quezon City Government as the petitioner, not to register the title in its name. The reconstituted title itself remained registered in the name of J.M. Tuason & Co. Inc. Regarding the discrepancy in the property area, the Court found that the notice of hearing, by attaching a copy of the original petition which included a copy of TCT No. 23110, sufficiently identified the property, and thus, there was no substantial discrepancy that would divest the court of jurisdiction.
Main Doctrine
Compliance with the mandatory and jurisdictional requirements of Republic Act No. 26, particularly regarding notice to occupants or persons in possession, is essential for a court to acquire jurisdiction over a petition for reconstitution of title. Failure to comply renders the proceedings and the decision void. However, non-compliance with LRC Circular No. 35 does not divest the trial court of jurisdiction.