Baguio Trinity Developers v. Heirs of Ramos
REITERATIONFacts
The Antecedents: The underlying dispute concerns the validity of reconstituted land titles. Spouses Meliton Grabiles and Leona Calderon were the original registered owners of a 2,933-square-meter lot. After several transfers, the lot was sold to petitioner Baguio Trinity Developers, Inc. in 1994, resulting in a new title in its name. However, two separate reconstitution proceedings were initiated in 1985 and 1986 for the Grabiles' original title. The first reconstitution resulted in a title issued in the name of Maria Bernal, while the second, purportedly on behalf of the Grabiles, led to a reconstituted title (OCT RO-4717) that noted prior sales to Jose Ramos and to spouses Leopoldo and Victorina Nepa. Respondents are the heirs of these buyers, Jose Ramos and the Nepas. Procedural History: Baguio Trinity Developers, Inc. filed a complaint for recovery and nullity of title in 1995 before the Municipal Trial Court (MTC), which dismissed it for lack of jurisdiction. A second complaint was filed in 1997 before the Regional Trial Court (RTC) of Agoo, Branch 32, for recovery of property, declaration of nullity of title, and damages. This RTC dismissed the complaint in 2004 for lack of jurisdiction and because it could not annul an order from a co-equal court. Baguio Trinity's subsequent petition for certiorari with the Court of Appeals (CA) was dismissed in 2007, with the CA suggesting a petition for annulment of judgment under Rule 47. Consequently, Baguio Trinity filed a petition for annulment of the RTC's reconstitution orders (dated October 20, 1986, and October 28, 1986) with the CA in December 2007. This petition was dismissed by the CA on May 8, 2008, for failure to attach a certified true copy of the assailed orders and for insufficient docket fees. A motion for reconsideration was denied on November 7, 2008, and a subsequent motion for reconsideration of that denial was also denied on April 24, 2009, leading to the present recourse. The Petition: Baguio Trinity Developers, Inc. filed a petition for annulment of judgment with the Court of Appeals, seeking to nullify the RTC's reconstitution orders of October 20, 1986, and October 28, 1986. The petitioner argued that the RTC lacked jurisdiction to order the reconstitution of the Grabiles' title because the original title was not lost and the Grabiles could not have authorized the proceedings as they were deceased. The CA dismissed the petition, citing two main grounds: first, the failure to attach a certified true copy of the assailed RTC orders as required by Rule 47 of the Rules of Court, and second, that the action was barred by laches, as Baguio Trinity had knowledge of the reconstitution orders since 1995 but filed the annulment petition 12 years later. The Supreme Court is asked to determine if the CA erred in dismissing the petition on these grounds.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for annulment of judgment for failure to attach a certified true copy of the assailed RTC orders. Whether the Court of Appeals erred in dismissing the petition for annulment of judgment on the ground of laches.
Ruling
The Court GRANTS the petition, sets aside the Court of Appeals Resolutions dated May 8, 2008, and November 7, 2008, and directs the Court of Appeals to hear and decide the merits of the petition for annulment of judgment.
Ratio Decidendi
On the failure to attach a certified true copy of the assailed RTC orders: The Court ruled that while Section 4, Rule 47 of the Rules of Court mandates the attachment of a certified copy of the judgment or final order, this requirement can be relaxed when the original records are lost or destroyed, as in this case due to the 1990 earthquake. The Court clarified that the administration of justice should not be halted due to such loss. When the record custodian can no longer issue a certified copy, the rules allow the submission of appropriate secondary evidence to prove the contents of the lost document, as provided in Section 5, Rule 130 of the Rules of Evidence. Petitioner's submission of authenticated copies of the challenged reconstitution orders, along with certified machine copies supplied by the LRA, constituted sufficient secondary evidence. The respondents' failure to question the authenticity of these copies further supported this. Therefore, the CA had no valid reason to deny the petition on this ground. On the ground of laches: The Court held that the CA erred in dismissing the action for annulment of final orders on the ground of laches. The Court found that petitioner Baguio Trinity had been diligently pursuing its remedies, albeit through a series of actions filed in different courts, which led to the delay. The dismissal of its initial actions by the MTC and RTC, and the CA's own suggestion to file under Rule 47, demonstrated that the petitioner was not guilty of inaction but was rather subjected to a procedural relay between lower courts. The Court emphasized that the petition alleged serious charges that could invalidate the respondents' titles, and the conflict between the two sets of titles covering the same property needed resolution. Allowing laches to bar the action would perpetuate an intolerable standoff in the titling system, which assures only one valid title per registered land. Thus, laches could not bar an action sought to resolve such a situation.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Court may be allowed to proceed despite the absence of a certified true copy of the assailed judgment or final order, provided that the unavailability of the certified copy is duly established, and the contents of the lost judgment or order are proven by secondary evidence. Furthermore, laches cannot bar an action to annul reconstitution orders when the petitioner has been diligently pursuing remedies, albeit through different courts, and the delay was caused by the procedural relay between lower courts.