Villanueva v. Viloria
REITERATIONFacts
The Antecedents: Respondent Francisco Viloria, through his Attorney-in-Fact Samuel P. Vera, filed a petition for the issuance of a new owner's duplicate copy of Transfer Certificate of Title (TCT) No. T-16156 before the Regional Trial Court (RTC) of Iba, Zambales, alleging that the original owner's duplicate copy was lost due to termite infestation after his wife's death in 1995. He claimed the title was irretrievably lost and executed an Affidavit of Loss. Procedural History: The RTC, finding the evidence meritorious, issued an Order on March 27, 2001, declaring the lost owner's duplicate copy of TCT No. T-16156 null and void and directing the Register of Deeds to issue a new one. This order became final and executory on April 11, 2001. Subsequently, a new owner's duplicate copy was issued. Respondent Viloria then executed an Affidavit of Self-Adjudication and sold the property covered by TCT No. T-16156 to Ruben M. Marty on March 4, 2002. Consequently, TCT No. T-16156 was cancelled and a new title was issued to Marty. The Petition: Petitioners learned about the RTC's order in March 2002 and filed a petition for annulment of judgment with the Court of Appeals (CA) on May 10, 2002, on grounds of lack of jurisdiction and extrinsic fraud. They claimed they were the actual possessors and owners of the land, having purchased it from the late wife of respondent Viloria, and were in possession of the original TCT No. T-16156. The CA dismissed their petition, finding that the RTC complied with the requirements for reconstitution and that the alleged fraud was not extrinsic. The CA also held that petitioners were not entitled to notice as their claim was not annotated on the title.
Issue(s)
Whether or not the Regional Trial Court had jurisdiction to order the issuance of a new owner’s duplicate copy of Transfer Certificate of Title No. 16156. Whether or not the Court of Appeals had decided the case in accordance with the applicable decisions of the Supreme Court on the matter.
Ruling
The petition is GRANTED. The Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 70560 are REVERSED and SET ASIDE. The Order of the Regional Trial Court of Iba, Zambales dated March 27, 2001 is DECLARED NULL and VOID for lack of jurisdiction.
Ratio Decidendi
On the issue of jurisdiction to order the issuance of a new owner’s duplicate copy of TCT No. 16156: The Supreme Court held that the Regional Trial Court did not acquire jurisdiction to order the reconstitution of the alleged lost owner's duplicate copy of TCT No. T-16156. This is because the title was not actually lost but was in the possession of the petitioners, who had purchased the property from its late owner. The Court reiterated its ruling in Strait Times, Inc. v. Court of Appeals and Demetriou v. Court of Appeals, stating that if an owner's duplicate copy of a certificate of title has not been lost but is in fact in the possession of another person, the reconstituted title is void and the court rendering the decision has not acquired jurisdiction. Consequently, the decision may be attacked at any time. The Court found that the petitioners presented proof of their possession of TCT No. T-16156 (Serial No. 2136412) and a copy of the sales contract dated June 5, 1986, duly signed by the late Cresencia P. Viloria, along with receipts of payment. The authenticity and genuineness of these documents were not disputed by the respondent. Therefore, as there was no proof of actual loss of the owner's duplicate copy, the trial court did not acquire jurisdiction, rendering the new title issued void. On whether the Court of Appeals decided the case in accordance with applicable Supreme Court decisions: The Supreme Court found that the Court of Appeals erred in dismissing the petition for annulment of judgment. The appellate court's reasoning that the failure to disclose matters that would defeat one's claim does not constitute extrinsic fraud was acknowledged, but the Court emphasized that such misrepresentation, even if not extrinsic fraud, can still be evidence of an absence of jurisdiction. The CA's reliance on the fact that petitioners' claim was not annotated on the title was also found to be misplaced in the context of a void judgment due to lack of jurisdiction. The Supreme Court's pronouncements in Rexlon Realty Group Inc. v. Court of Appeals, which cited Strait Times, Inc. v. Court of Appeals and Demetriou v. Court of Appeals, were deemed directly applicable. These cases establish that a reconstituted title is void and the court lacks jurisdiction if the original duplicate title was not lost but was in the possession of another party. The CA's decision was not in consonance with these established precedents, leading to the reversal.
Main Doctrine
A court rendering a decision ordering the reconstitution of a title does not acquire jurisdiction if the owner's duplicate copy of the title has not been lost but is in fact in the possession of another person. Consequently, the decision may be attacked at any time.