Kuli v. Pia
REITERATIONFacts
The Antecedents: Petitioners, heirs of Datu Kuli, claim ownership over Lot 2327, originally titled under Datu Kuli's name via OCT No. 1654. Upon Datu Kuli's death, possession passed to his heirs. When petitioners sought title reconstitution, they discovered a TCT No. 1608 in the name of respondent Daniel R. Pia, allegedly based on a Deed of Sale from Datu Kuli. This title was subsequently cancelled and new titles were issued in the names of respondents Filomena Follosco and Jose Follosco, Sr. Procedural History: Petitioners filed a Complaint for Quieting of Title, praying for the annulment of subsequent titles and restoration of OCT No. 1654. Summons could not be served on respondents, leading to service by publication and their subsequent declaration in default. The RTC dismissed the case, upholding the validity of TCT No. 1608 and subsequent titles, finding that petitioners failed to overcome the presumption of regularity in their issuance. The CA affirmed the RTC's decision. The Petition: Petitioners seek reversal of the CA decision, arguing that the CA erred in upholding the validity of TCT 1608.
Issue(s)
Whether the petitioners failed to establish a valid cause of action for quieting of title, and whether the issuance of Transfer Certificate of Title (TCT) No. 1608 in the name of Daniel R. Pia is valid. Whether the subsequent transfers and issuances of TCT No. T-374 and TCT No. T-2911 in the names of Filomena Follosco and Jose Follosco, Sr., respectively, are valid. Whether the administrative reconstitution of TCT 1608 is valid.
Ruling
The Petition is denied. The Court affirms the appreciation of the evidence by the CA and the RTC. The dispositive portion of the RTC judgment, which was affirmed by the CA, is upheld.
Ratio Decidendi
On the failure to establish a valid cause of action and the validity of TCT 1608: The Court reiterated that an action for quieting of title requires the plaintiff to have legal or equitable title and that the cloud on the title must be shown to be invalid or inoperative. While petitioners' possession might establish their interest, they failed to prove that respondent Pia did not present a valid Deed of Sale or that such deed was invalid. The Register of Deeds' inability to produce the Deed of Sale was explained by the mutilation of records. Crucially, the Register of Deeds issued a certification showing an entry in its Primary Entry Book for a Deed of Sale executed by Datu Dalandag Kuli in favor of Daniel R. Pia on December 21, 1940, for P390.00. This notation, despite the dilapidated condition of the original document, sufficiently proved that the deed was presented and registered, leading to the cancellation of OCT No. 1654 and the issuance of TCT 1608 in accordance with Section 57 of the Property Registration Decree. Petitioners' bare allegation of non-sale was insufficient to defeat the presumption of regularity of TCT 1608. On the validity of subsequent transfers: Since the Court upheld the validity of TCT 1608, it follows that the subsequent transfers and issuances of TCT No. T-374 in the name of Filomena Follosco and TCT No. T-2911 in the name of Jose Follosco, Sr., which were derived from TCT 1608, are also valid. The petitioners failed to cast doubt on the validity of the derivative titles. On the validity of the administrative reconstitution of TCT 1608: The Court found that the administrative reconstitution of TCT 1608 was conducted in accordance with Republic Act No. 26, which provides the procedure for reconstituting lost or destroyed titles. The law prioritizes the owner's duplicate of the certificate of title as a source for reconstitution. The presence of the owner's duplicate of TCT 1608 in the Register of Deeds made it unnecessary to compel respondent Pia to produce his copy. Therefore, the administratively reconstituted TCT 1608 was validly issued.
Main Doctrine
The failure of the Register of Deeds to produce a copy of a Deed of Sale, after a new title has been issued, is not sufficient evidence to prove that the claimed sale never occurred, especially when the Register of Deeds certifies that such a document was once registered and its records are now mutilated.