Dizon v. Philippine Veterans Bank
REITERATIONFacts
The Antecedents: Spouses Rogelio and Corazon Dizon mortgaged three parcels of land to Philippine Veterans Bank (PVB) as security for a credit accommodation. The Spouses Dizon failed to pay their obligation, leading to the extrajudicial foreclosure of the mortgage. PVB acquired the properties at a public auction on December 8, 1983, and a Certificate of Sale was issued and registered on November 22, 1984. Procedural History: In June 1986, PVB filed a petition for the issuance of an owner's duplicate certificate of title, which was dismissed without prejudice due to failure to prosecute. PVB filed a new petition on July 26, 1999 (L.R.C. Case No. A-124-1024). Rogelio Dizon opposed this petition. Separately, PVB filed an ex-parte petition for a writ of possession (Cad. Case No. A-124-1057), which was initially granted by the RTC but reversed and dismissed by the CA. In L.R.C. Case No. A-124-1024, the RTC granted PVB's petition for the issuance of new owner's duplicate copies of the titles. Rogelio Dizon appealed to the CA, which dismissed his appeal for failure to file an appellant's brief. The CA denied his motion for reconsideration. The Petition: Rogelio Dizon filed a petition for review on certiorari with the Supreme Court, raising issues of prescription, the authenticity of titles, perjury, and the validity of documentary bases for the second petition.
Issue(s)
Whether the petition for the issuance of an owner's duplicate copy of title filed by respondent bank has prescribed. Whether the titles presented by petitioner to the bank were genuine and whether the petitioner is estopped from questioning the authenticity of these titles. Whether the Head of PVB's Assets Recovery Department committed perjury in her sworn affidavit of loss and whether the documentary bases for the second petition are sufficient. On the nature of the petition for issuance of a second owner's duplicate copy of a title.
Ruling
The Supreme Court denied the petition and affirmed the Resolutions of the Court of Appeals. The Court found no merit in the petitioner's arguments, upholding the RTC's decision to grant PVB's petition for the issuance of owner's duplicate certificates of title.
Ratio Decidendi
On the issue of prescription: The Court held that PVB's petition for the issuance of an owner's duplicate certificate of title is not a mortgage action and therefore not subject to the ten-year prescriptive period under Article 1142 of the Civil Code. The petition arises from PVB's right as the owner of the properties, not as a mortgagee, as the mortgage had already been foreclosed and the properties sold. Furthermore, Presidential Decree (PD) No. 1529, which governs petitions for the replacement of lost duplicate certificates of title, does not provide for any limitation or prescriptive period for filing such a petition. The silence of the law on this matter indicates no intention to impose a prescriptive period. On the issue of title authenticity and estoppel: The Court found petitioner's allegations regarding the alteration of titles to be unsubstantiated and self-serving. The Court noted that petitioner and his wife voluntarily submitted the authentic owner's duplicate titles to PVB for the loan. Therefore, petitioner is estopped from questioning the authenticity of these titles, which he used to obtain the loan and from which he derived benefit. The doctrine of estoppel prevents him from adopting an inconsistent position to the prejudice of the respondent bank, which relied on his representations. The Court found his opposition to be a desperate attempt to cling to properties he legally lost due to foreclosure. On the issues of perjury and documentary bases: The Court ruled that the issues raised by the petitioner involve questions of fact, which are generally not within the jurisdiction of the Supreme Court in a petition for review on certiorari under Rule 45. The Court is not a trier of facts and does not analyze or weigh evidence. While exceptions exist, the present case does not fall under any of them. The Court gave full faith and credence to the RTC's finding that the owner's duplicate copies were lost, consistent with the rule that appellate courts should not reverse trial court findings of fact without strong reasons. The Court also found PVB's submission of certified true copies from the Register of Deeds to be a compliance with the jurisdictional requirement under Section 109 of PD No. 1529, which requires a sworn statement of loss or destruction. On the nature of the petition: The Court reiterated that in a petition for the issuance of a second owner's duplicate copy of a title, the only questions to be resolved are whether the original owner's duplicate copy has been lost and whether the petitioner is the registered owner or a person in interest. The RTC found that the original owner's duplicate copies were lost, and PVB, having acquired the properties at public auction, is a person in interest. The Court found no dispute regarding the identity of the properties, the mortgage, the failure to pay obligations, or the validity of the foreclosure proceedings and PVB's acquisition of the properties.
Main Doctrine
A petition for the issuance of an owner's duplicate certificate of title under PD 1529 does not prescribe, as the law is silent on any prescriptive period for filing such petition. Furthermore, a party who voluntarily submitted titles to a bank for a loan and subsequently benefited from the contract is estopped from questioning the authenticity of those titles when the bank seeks to replace lost duplicate copies after acquiring the property through foreclosure.