Republic v. Dela Raga
REITERATIONFacts
The Antecedents: Agripina dela Raga, as the granddaughter and sole heir of Ignacio Serran and Catalina Laguit, sought the reconstitution of Original Certificate of Title (OCT) No. 49266, covering a 79,570-square meter parcel of land in Sison, Pangasinan. Dela Raga claimed to have inherited the property from her deceased parents and grandparents, and that she had been in possession of the land, paying taxes thereon. She asserted that the owner's duplicate copy of OCT No. 49266 was lost, and the original copy in the Register of Deeds was destroyed during World War II. Procedural History: The respondent, Agripina dela Raga, filed a petition for the reconstitution of OCT No. 49266 with the Regional Trial Court (RTC), Branch 47, Urdaneta, Pangasinan. The RTC granted the petition, finding that Dela Raga had proven her relationship to Ignacio Serran, that the property was covered by OCT No. 49266, that the original title was destroyed, and that Dela Raga had complied with all jurisdictional requirements. The Republic of the Philippines appealed this decision to the Court of Appeals. The Court of Appeals affirmed the RTC's decision in its entirety. The Republic then filed the present petition for review on certiorari. The Petition: The petitioner, the Republic of the Philippines, filed this petition for review on certiorari under Rule 45 of the Rules of Court, challenging the Court of Appeals' decision. The Republic's sole assigned error is that the Court of Appeals erred in not finding that the respondent failed to prove that the Original Certificate of Title was valid and subsisting at the time of its alleged loss or destruction. The Republic argued that the certification from the Register of Deeds was insufficient as it did not explicitly state the title's validity and subsistence at the time of loss, nor did it confirm the absence of other titles or transactions affecting the property, as required by LRA Circular No. 35.
Issue(s)
Whether respondent Dela Raga failed to prove that the Original Certificate of Title was valid and subsisting at the time of its alleged loss or destruction. Whether the Court of Appeals erred in affirming the RTC's decision granting the petition for reconstitution.
Ruling
The Court denied the petition and affirmed the Decision of the Court of Appeals, upholding the reconstitution of OCT No. 49266.
Ratio Decidendi
On the failure to prove the validity and subsistence of the OCT at the time of loss: The Court reiterated that the sufficiency of the Register of Deeds' report is not an indispensable requirement in reconstitution cases and may even be disregarded. Citing Section 15 of Republic Act No. 26, the Court emphasized that if the court, after hearing, finds the presented documents and evidence sufficient and proper to warrant reconstitution, and that the petitioner has an interest in the property, the certificate of title was in force at the time of loss, and the description, area, and boundaries are substantially the same, an order of reconstitution shall be issued. The RTC found Dela Raga's evidence sufficient and proper, and this finding, affirmed by the CA, is binding on the Supreme Court unless exceptions apply, which were not demonstrated by the Republic. The Court also noted that the Republic did not show that the case fell under any of the exceptions to the rule that factual findings of the RTC, affirmed by the CA, are binding. On the alleged error of the Court of Appeals: The Court found no reversible error in the CA's affirmation of the RTC's decision. The CA correctly held that the Republic failed to show substantial and convincing evidence to rebut the RTC's factual findings. The CA also correctly found the Republic's argument regarding the insufficiency of the Register of Deeds' report to be unsubstantial. The Court reiterated the principle that factual findings of the trial court, especially when affirmed by the appellate court, are binding on the Supreme Court, and the Republic failed to establish any of the recognized exceptions to this rule. The Court also pointed out that the duty to issue an order of reconstitution becomes mandatory once the court finds the evidence sufficient and proper, and all basic requirements have been complied with, as held in Republic v. Casimiro.
Main Doctrine
The sufficiency of the Register of Deeds' report is not an indispensable requirement in reconstitution cases, and such report may even be disregarded. Compliance with jurisdictional requirements and presentation of sufficient evidence warrant the issuance of an order of reconstitution.