Republic v. Alonte
REITERATIONFacts
The Antecedents: Respondent Lourdes F. Alonte filed a petition for the reconstitution of the original of Transfer Certificate of Title (TCT) No. 335986 and the issuance of the corresponding owner's duplicate copy. The title purportedly covers Lot 18-B of a subdivision plan, with an area of 80.95 square meters, situated in what is now Quezon City. Alonte alleged that she is the owner in fee simple of the property and that the original copy of the title, which was kept in the Office of the Register of Deeds of Quezon City, was destroyed or burned during a fire on June 11, 1988. She further claimed that the owner's duplicate copy of the title was lost, for which an affidavit of loss was executed and filed. Procedural History: The petition for reconstitution was filed with the Regional Trial Court (RTC) of Quezon City, Branch 82. After notice and hearing, where the petitioner was represented by her attorney-in-fact, the RTC granted the petition on August 13, 2002, directing the Register of Deeds to reconstitute the original TCT and issue a new owner's duplicate copy. A Certificate of Finality was initially issued, but it was later revoked when the Office of the Solicitor General filed a Notice of Appeal. The case was elevated to the Court of Appeals (CA), which affirmed the RTC's decision on February 26, 2004. The CA found that the RTC did not err in ordering the reconstitution based on a photocopy, applying Section 3(f) of Republic Act No. 26. The Petition: The Republic of the Philippines, through the Office of the Solicitor General, filed the present Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. The petitioner argues that the CA erred in finding sufficient basis for the reconstitution and in affirming the RTC's decision despite alleged non-compliance with mandatory requirements under Republic Act No. 26. Specifically, the petitioner contends that the trial court failed to acquire jurisdiction because the petition did not state the names and addresses of occupants, adjoining owners, and interested parties; a detailed description of encumbrances; and restrictions and liabilities. Furthermore, the petitioner claims the petition lacked the required approved plan and technical description, a tracing cloth plan, and proof of registration of the affidavit of loss with the Register of Deeds.
Issue(s)
Whether the Court of Appeals erred in finding that there is sufficient and proper basis for the reconstitution of TCT No. 335986 and whether the respondent complied with the requirements of Sections 12 and 13 of R.A. No. 26. Whether the Court of Appeals erred in affirming the lower court's decision granting the petition for reconstitution despite the respondent's alleged failure to comply with the mandatory requirements prescribed under Republic Act No. 26, specifically regarding the Affidavit of Loss.
Ruling
The petition is unmeritorious. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the sufficiency of basis for reconstitution and compliance with R.A. No. 26 (Sections 12 and 13): The Supreme Court reiterated its ruling in Republic of the Philippines v. Casimiro, emphasizing that findings of fact by the RTC, affirmed by the CA, are generally conclusive and binding upon the Supreme Court. The Court is not a trier of facts and will not disturb such findings unless there are compelling or exceptional reasons, which were not present in this case. The petitioner failed to present any such reasons to deviate from the established rule. Both the RTC and the CA found the evidence presented by the respondent adequate to order the reconstitution of TCT No. 335986. The Court found no factual basis for the petitioner's claim that the respondent failed to comply with the requirements of Sections 12 and 13 of R.A. No. 26. The petition alleged possession, listed adjoining owners, stated the title was free from encumbrances, and attached a copy of TCT No. 335986, making its contents part of the petition. Furthermore, the petition was accompanied by a technical description approved by the Commissioner of the National Land Titles and Deeds Registration Administration, satisfying the requirements of Section 12 of R.A. No. 26. The Court also noted that the possession by the respondent's attorney-in-fact, Editha Alonte, was in the name of the respondent, supported by the payment of real property taxes declared in the respondent's name. The Land Registration Authority's report verified the correctness of the plan and technical description, further supporting compliance with the law. On the Affidavit of Loss: The Court found that the Affidavit of Loss had been submitted to the Register of Deeds, as indicated by an inscription on the photocopy of the TCT.
Main Doctrine
The findings of fact of the RTC, affirmed by the Court of Appeals, are generally conclusive and binding upon the Supreme Court, and will not be disturbed absent compelling or exceptional reasons. The Court is not a trier of facts, its jurisdiction being limited to errors of law.