Guido-Enriquez v. Victorino
REITERATIONFacts
The Antecedents: In February 1980, Antonia Vda. De Victorino filed an Application for Registration of Title over a 10,603 square-meter lot in Binangonan, Rizal, claiming ownership through purchase and adverse possession. The Republic opposed, asserting the lot belonged to the Philippines. Reports indicated potential overlaps with other titles and a pending case (Guido Case) concerning the mother title (TCT No. 23377). Despite initial delays and conflicting survey reports, the RTC-Pasig granted Antonia Victorino's application on August 15, 1988, confirming her title. An Order for Issuance of Decree was issued, but the Land Registration Authority (LRA) held it in abeyance pending the Guido Case resolution. Procedural History: The Supreme Court, in G.R. No. 84966 (November 21, 1991), ruled in favor of the Guido heirs regarding TCT No. 23377 but acknowledged the superior rights of bona fide occupants with registered titles or long-standing possession amounting to ownership. Subsequently, on May 21, 2001, Alicia Victorino, as transferee of Antonia Victorino, filed a motion for an alias order for issuance of a decree, noting Antonia's death. The LRA stated the lot was deemed excluded from TCT No. 23377 and an annotation was imperative. On November 19, 2002, the RTC-Pasig granted the motion, ordering the LRA to issue the decree and the Register of Deeds to annotate the decisions on TCT M-2102, effectively segregating Antonia's portion. Petitioner Crisanta Guido-Enriquez moved for clarification, arguing the November 19, 2002 Order modified the August 15, 1988 Decision. The RTC denied this motion on March 6, 2003, and ordered the issuance of the decree. Further motions for reconsideration were denied. The Court of Appeals (CA) affirmed the RTC's orders, with modification denying the prayer for issuance of the decree in Alicia Victorino's name but affirming the segregation and annotation. The Petition: Petitioner seeks to reverse the CA's decision, arguing that the RTC's orders, particularly the November 19, 2002 Order, effectively modified the August 15, 1988 Decision, deprived them of property without due process, and that the RTC, acting as a land registration court, lacked jurisdiction to segregate a portion already covered by an indefeasible title (TCT M-2102). Petitioner also questions the appropriateness of the RTC proceeding for segregation and the participation of a justice who previously ruled on the RTC decision.
Issue(s)
Whether the RTC's November 19, 2002 Order and subsequent orders modifying the August 15, 1988 Decision are valid. Whether the RTC, as a land registration court, had jurisdiction to order the segregation of a portion of land already covered by an indefeasible title (TCT M-2102). Whether the proceedings denied petitioner her right to due process. Whether the RTC proceeding was the appropriate venue contemplated by the Supreme Court in the Guido case for determining the rights of bona fide occupants. Whether a justice who previously rendered the RTC decision should have been disqualified from participating in the CA review.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed. The RTC's orders, including the November 19, 2002 Order directing the annotation and segregation, are upheld as they give effect to the Supreme Court's pronouncements in the Guido case regarding bona fide occupants.
Ratio Decidendi
On the validity of the RTC's November 19, 2002 Order and subsequent orders: The Court held that the August 15, 1988 Decision of the RTC had already become final and executory. Under the doctrine of immutability of judgment, a final decision cannot be modified. However, the subsequent orders did not modify the August 15, 1988 Decision but rather gave effect to it in light of the Supreme Court's ruling in the Guido case. The Supreme Court's decision in Republic v. Court of Appeals (G.R. No. 84966) acknowledged the superior rights of bona fide occupants, and the RTC's subsequent actions were aimed at implementing this recognition. The Court found no error in the CA's affirmation of these orders, as they were consistent with the established jurisprudence. On the jurisdiction of the RTC and segregation of title: The Court rejected the argument that the RTC lacked jurisdiction to order segregation because the lot was within TCT No. M-2102. It reiterated the Supreme Court's ruling in the Guido case, which recognized that while TCT No. 23377 (and its derivatives like TCT M-2102) evidenced indefeasible title, equitable presumption of laches could apply against the titleholders for their failure to assert ownership. The Court emphasized that the Guido ruling mandated that bona fide occupants, like Antonia Victorino, prove their claims in an appropriate proceeding. The RTC's decision granting Antonia's application was deemed such an appropriate proceeding where her bona fide occupancy was proven. Therefore, the segregation and annotation were necessary to give effect to these recognized rights. On the denial of due process: The Court found no denial of due process. Regarding the failure to identify petitioner as an indispensable party or serve her personal notice, the Court noted that Section 15 of PD 1529 requires stating the names and addresses of occupants and adjoining owners if known. Antonia Victorino's application stated, to her knowledge, no one else had an interest or was in possession. The Court reiterated that land registration proceedings are in rem, and personal notice to all owners or claimants is not strictly necessary to vest the court with jurisdiction over the res. Since no issue was raised regarding notice and publication, petitioner was deemed sufficiently notified. On the appropriateness of the RTC proceeding: The Court found no repugnancy between the Supreme Court's decision in the Guido case and the RTC's August 15, 1988 Decision. The RTC's proceeding was considered the appropriate venue contemplated by the Supreme Court to prove bona fide occupancy, as Antonia Victorino had already established her claim during that process. To require another proceeding would be redundant. The Court cited E. Rommel Realty and Development Corporation v. Sta. Lucia Realty Development Corporation to support the principle that a prior application for registration can serve as the appropriate proceeding to prove bona fide occupancy. On the disqualification of Justice Villarama, Jr.: The Court affirmed the CA's ruling that there was no ethical or legal impediment to Justice Villarama, Jr.'s participation. The CA correctly pointed out that the August 15, 1988 RTC Decision, which Justice Villarama, Jr. penned, had already become final and executory and was not the subject of review in the certiorari petition. The issues under review pertained to the subsequent orders issued by Justice Villarama, Jr.'s successor. Therefore, Rule 137 of the Rules of Court, prohibiting a judge from sitting in review of a ruling he made in an inferior court, was not violated.
Main Doctrine
A final and executory judgment is immutable and unalterable. While a land registration case is a proceeding in rem, the rights of bona fide occupants, even if not initially identified in the application, may be recognized and given effect, especially when supported by prior Supreme Court rulings acknowledging such rights.