Philippine Veterans Bank v. Valenzuela
REITERATIONFacts
The Antecedents: Philippine Veterans Bank (PVB) granted a loan of P6,000,000.00 to Cafe Valenzuela, Inc. As security, a Real Estate Mortgage (REM) was executed, covering several parcels of land, including one registered under TCT No. T-105375 in the name of Spouses Maximo and Honorata Valenzuela. Cafe Valenzuela, Inc. defaulted on its loan obligation. PVB initiated an extra-judicial foreclosure of the REM, and the property was sold at public auction, with PVB emerging as the highest bidder. A certificate of sale dated July 31, 1985, for P1,923,878.40 was issued to PVB. Procedural History: PVB filed a petition with the Regional Trial Court (RTC) of Malolos, Bulacan, on June 27, 1997, seeking the correction of Entry No. 9242 on TCT No. T-105375 (later reconstituted as TCT No. RT-35677). PVB alleged that this entry erroneously reflected the contents of a different certificate of sale (P31,496.00 dated April 15, 1986) instead of the correct certificate of sale dated July 31, 1985 (P1,923,878.40). Respondent Ramon Valenzuela, one of the registered owners' children, opposed the petition, arguing that Enrico Valenzuela lacked authority to mortgage the property and that the certificate of sale was never duly registered. The RTC initially ordered the correction of the entry on April 30, 2002. However, upon respondent's motion for reconsideration, the RTC, on November 4, 2003, set aside its earlier order and dismissed PVB's petition, relying on a Court of Appeals (CA) resolution that found the certificate of sale was never registered. The Petition: Petitioner Philippine Veterans Bank filed the present petition for review on certiorari under Rule 45 of the Rules of Court, assailing the RTC's November 4, 2003 Order that dismissed its petition for correction of entry. PVB contends that the RTC erred in relying on the CA's November 14, 2002 Resolution, which it claims erroneously ruled that a previous RTC order constituted res judicata on the issue of non-registration. PVB argues that the CA's finding of non-registration was erroneous and that the matter of correcting the entry should have been decided on its merits. The Supreme Court, however, found the petition to be without merit, affirming the RTC's dismissal based on the finality of the CA's resolution which established that the certificate of sale was not registered, thus precluding any correction under Section 108 of PD No. 1529.
Issue(s)
Whether the Regional Trial Court erred in relying on the November 14, 2002 Resolution of the Court of Appeals in dismissing petitioner's petition for correction of entry. Whether a petition for correction of entry under Section 108 of PD 1529 can be used to resolve controversial issues involving adverse claims and disputed facts.
Ruling
The petition is denied. The November 4, 2003 Order of the Regional Trial Court of Malolos, Bulacan, Branch 8, is affirmed.
Ratio Decidendi
On the issue of whether the RTC erred in relying on the CA Resolution: The Supreme Court held that the November 14, 2002 Resolution of the CA, which had become final and executory, established the factual finding that the Certificate of Sale involving TCT No. T-105375 was not registered with the Register of Deeds of Bulacan. Since this finding attained finality, neither the RTC nor the Supreme Court could reopen or relitigate this factual issue between the same parties. The Court reiterated the principle that a judgment that has become final and executory is immutable and unalterable, with no exceptions applicable in this case. Therefore, the RTC did not err in relying on the CA's final resolution. On the issue of whether a petition for correction of entry under Section 108 of PD 1529 can be used to resolve controversial issues: The Supreme Court affirmed that proceedings under Section 108 of PD 1529 are summary in nature and are intended for the correction of clerical mistakes or errors that are not controversial. Relief under this section can only be granted if there is unanimity among the parties or no adverse claim or serious objection from any interested party. In this case, respondent Valenzuela's opposition, motion to dismiss, and pending civil case for annulment of title clearly demonstrated a serious objection and an adverse claim. The RTC had previously found in the civil case that the certificate of sale was not registered, which prevented the one-year redemption period from running. Consequently, PVB could not avail itself of the remedy under Section 108 of PD 1529, as it involved a controversial issue that required an ordinary civil action.
Main Doctrine
A petition for correction of entry under Section 108 of PD 1529 is summary in nature and contemplates corrections of clerical mistakes, not controversial issues involving adverse claims or serious objections. If such controversial issues exist, the proper recourse is an ordinary civil action.