Republic v. Zoomak R.P.C.
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the reconstitution of a lost or destroyed Original Certificate of Title (OCT) for Lot 1950 of the Longos Cadastre, Laguna. This lot, with an area of almost one hectare, was originally adjudicated to Teresa Macawili by the land registration court on January 7, 1930, with Decree 416517 issued on December 26, 1930. Both Teresa Macawili's owner's duplicate copy of the OCT and the Register of Deeds' copy were lost or destroyed during World War II. Respondent Zoomak R.P.C., Inc. (Zoomak) acquired the land in 1996 from Nestor Macawili, Jr., who had purchased it from Teresa Macawili's sole heir. 2. Procedural History: On February 26, 1998, Zoomak filed a petition with the Regional Trial Court (RTC) of Sta. Cruz, Laguna, seeking the reconstitution of the lost title for Lot 1950. The RTC granted Zoomak's petition on January 18, 2000, ordering the Laguna Register of Deeds to reconstitute the OCT. The Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed this decision to the Court of Appeals (CA). On May 31, 2007, the CA dismissed the Republic's appeal and affirmed the RTC's decision. 3. The Petition: The Republic of the Philippines, represented by the OSG, filed a petition for review on certiorari with the Supreme Court, arguing that the CA erred in affirming the RTC's decision. The petition challenges the sufficiency of the evidence presented by Zoomak for the reconstitution of the title, specifically questioning the admissibility and probative value of an LRA certification and an RTC certification, and the absence of a report from the LRA on the plan and technical descriptions. The core of the Republic's argument is that the evidence presented by Zoomak was insufficient to establish the existence of the lost title as required by Republic Act No. 26.
Issue(s)
Whether or not the Court of Appeals erred in affirming the Regional Trial Court's Decision that granted Zoomak's application for the reconstitution of Teresa Macawili's lost title over the subject property.
Ruling
The Court denies the petition and affirms the Court of Appeals decision in CA-G.R. CV 66572 dated May 31, 2007.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the Regional Trial Court's Decision that granted Zoomak's application for the reconstitution of Teresa Macawili's lost title over the subject property: The Court held that the reconstitution of a certificate of title under Republic Act No. 26 denotes the restoration in the original form and condition of a lost or destroyed instrument, attesting to a person's title to a piece of land. The purpose is to have the title reproduced exactly as it was before its loss or destruction, following legal procedures. The Court noted that one of the pieces of evidence presented by Zoomak was a Land Registration Authority (LRA) certification stating that a decree was issued in favor of Teresa Macawili. Although the OSG contended that this certification was not signed by the authorized officer and was a mere photocopy, the Court found that the government did not object to its admission during the hearing. The rule is that failure to object to evidence when offered is deemed an agreement to its admission, even if it is otherwise inadmissible. While the OSG argued that admissibility differs from probative value, the determination of probative value is left to the court deciding the merits of the case. Both the trial court and the CA found the certifications worthy of belief and essential proof of the lost title. Furthermore, the Court pointed out that the RD's Certification stating that Lot 1950 was not covered by any title as of September 16, 1997, only indicated its status at that specific time and did not preclude the prior existence of a registered title that was subsequently lost or destroyed. The private documents presented also merely showed that the lot was not registered at the time of their execution, which is consistent with the title being lost and awaiting reconstitution. Regarding the LRA's non-submission of a report on the plan and technical descriptions, the RTC considered this a waiver by the LRA, an agency of the Republic, of its opportunity to contest their correctness. The Court found no fault with the RTC's stance, as the plan and technical descriptions are considered additional requirements under Section 2(f) of R.A. 26, not the sole sources for reconstitution.
Main Doctrine
The failure of the government to object to the admission of evidence, even if it is inadmissible, results in its deemed admission. The determination of the probative value of such evidence rests with the court.