Saint Mary Crusade v. Riel
REITERATIONFacts
The Antecedents: The underlying dispute concerns a petition for the judicial reconstitution of Original Certificate of Title (OCT) No. 1609 of the Register of Deeds of Quezon City. The petitioner, Saint Mary Crusade to Alleviate Poverty of Brethren Foundation, Inc., claimed that the original copy of the title was lost or destroyed in a fire that gutted the Register of Deeds office in the late 1980s. The University of the Philippines (UP) has a registered ownership over the land in question, a fact that has been consistently upheld by the Supreme Court in numerous prior decisions. Procedural History: The petitioner filed a petition for judicial reconstitution with the Regional Trial Court (RTC) of Quezon City, Branch 85. Initially, the RTC gave due course to the petition. However, after receiving a report from the Land Registration Authority (LRA) recommending dismissal and considering the oppositions filed by the Republic of the Philippines and the University of the Philippines, the RTC dismissed the petition for reconstitution. The petitioner moved for reconsideration, attaching several supporting documents. The RTC denied this motion, prompting the petitioner to file a petition for certiorari and mandamus directly with the Supreme Court. The Petition: The petitioner seeks certiorari and mandamus to assail the RTC's dismissal of its petition for reconstitution and the subsequent denial of its motion for reconsideration. The petitioner alleges that the respondent Judge committed grave abuse of discretion and unlawful neglect of duty. The petition argues that the dismissal was improper as the petitioner was not given an opportunity to comment on the LRA's recommendation or to controvert the oppositions. The petitioner contends that the LRA report was unsubstantiated and its veracity questionable. The petitioner further argues that the RTC should have allowed the reconstitution despite the established ownership of the UP, as the petitioner was not afforded a chance to present its case fully.
Issue(s)
Whether the respondent Judge committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the petition for judicial reconstitution. Whether the petitioner availed itself of the correct remedies by filing a petition for certiorari and mandamus instead of an appeal. Whether the petitioner complied with the requirements of Republic Act No. 26 for the judicial reconstitution of a Torrens title. Whether the petitioner correctly observed the doctrine of hierarchy of courts.
Ruling
The petition for certiorari and mandamus is dismissed for lack of procedural and substantive merit. The Court orders the petitioner to pay the costs of suit.
Ratio Decidendi
On the alleged grave abuse of discretion: The RTC, as the successor of the Court of First Instance, has original and exclusive jurisdiction over petitions for judicial reconstitution of title under Section 12 of Republic Act No. 26. Therefore, the RTC did not lack or exceed its authority in acting on and dismissing the petition. The dismissal was justified as the land involved was already registered in the name of the UP, as confirmed by the LRA. It would have been contrary to law for the RTC to grant the petition under these circumstances. The land in question is part of the UP campus, and its ownership by the UP has been long settled by the Supreme Court. The dismissal of the petition for reconstitution by the RTC served to protect the UP's registered ownership, aligning with previous admonitions by the Court against entertaining spurious cases assailing UP's title. On the availability of certiorari and mandamus as remedies: Certiorari is an extraordinary remedy granted only when the respondent tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion, and there is no appeal, or any plain, speedy, and adequate remedy in the ordinary course of law. The assailed orders of the RTC finally disposed of the application for judicial reconstitution. Thus, the proper recourse for the petitioner was to file a notice of appeal within the reglementary period. By failing to do so, the petitioner squandered its right to appeal, and certiorari cannot be used as a substitute for a lost appeal. On compliance with Republic Act No. 26: The petitioner failed to present the duplicate or certified copy of OCT No. 1609, which is a primary requirement under Sections 2 and 3 of Republic Act No. 26 for the judicial reconstitution of a Torrens title. The other documents presented were not sufficient bases for reconstitution, especially considering that the land was already registered in the name of the UP, a fact settled in numerous previous cases. On the observance of the hierarchy of courts: The petitioner filed the special civil action for certiorari and mandamus directly with the Supreme Court, disregarding the doctrine of hierarchy of courts. While the Supreme Court has concurrent jurisdiction with the Court of Appeals over such actions, direct resort is permissible only when there are special, extraordinary, or compelling reasons, which were absent in this case. The observance of this doctrine is crucial to allow the Supreme Court to focus on more fundamental tasks.
Main Doctrine
A petition for the judicial reconstitution of a Torrens title must strictly comply with the requirements prescribed in Republic Act No. 26; otherwise, the petition should be dismissed. Certiorari and mandamus are not substitutes for a lost appeal, and direct resort to the Supreme Court is only allowed under exceptional circumstances, disregarding the doctrine of hierarchy of courts.