Sebastian v. Cruz
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of land located in Brgy. Bogtong-Bolo, Mangatarem, Pangasinan, covered by OCT No. P-41566. Respondent Nelson C. Cruz, married to Cristina P. Cruz, is the registered owner. In November 2009, Nelson, through his father and attorney-in-fact Lamberto P. Cruz, allegedly sold the land to petitioner Joy Vanessa M. Sebastian. Sebastian paid the purchase price, received possession of the land, the owner's duplicate copy of OCT No. P-41566, and other pertinent documents. She also paid the capital gains tax. However, when Sebastian presented these documents to the Register of Deeds for the Province of Pangasinan (RD-Pangasinan) to transfer the title to her name, she was instructed to obtain a Special Power of Attorney from the Spouses Cruz authorizing Lamberto to sell the land. Lamberto failed to provide this document. Consequently, Sebastian filed an adverse claim on OCT No. P-41566 on August 2, 2011, to protect her interest. 2. Procedural History: Sebastian discovered on July 14, 2014, that the Spouses Cruz had filed a petition for the issuance of a second owner's copy of OCT No. P-41566 before the Regional Trial Court (RTC) of Lingayen, Pangasinan, Branch 69, docketed as LRC Case No. 421. This petition was based on Nelson Cruz's Affidavit of Loss dated September 23, 2013, attesting to the loss of the owner's duplicate copy of OCT No. P-41566. On March 27, 2014, the RTC granted the Spouses Cruz's petition and ordered the issuance of a new owner's duplicate copy of OCT No. P-41566 in their names. Believing the RTC lacked jurisdiction because the duplicate title was not lost but was in her possession, Sebastian filed a petition for annulment of judgment before the Court of Appeals (CA). The CA, in its Resolutions dated March 13, 2015, and October 9, 2015, dismissed Sebastian's petition outright, holding that the RTC had acquired jurisdiction due to compliance with publication and notice requirements. 3. The Petition: Aggrieved by the CA's dismissal, Sebastian filed the present petition for review on certiorari under Rule 45 of the Rules of Court. She argues that the CA erred in denying due course to her petition for annulment of judgment and dismissing it outright. Sebastian contends that the RTC lacked jurisdiction to issue an order for the reconstitution of the owner's duplicate copy of OCT No. P-41566 because the said duplicate copy was not lost, but was in her possession. She asserts that a judgment rendered without jurisdiction is void and can be annulled. The core issue before the Supreme Court is whether the CA correctly denied due course to Sebastian's petition for annulment of judgment.
Issue(s)
Whether the Court of Appeals (CA) correctly denied due course to Sebastian's petition for annulment of judgment and dismissed it outright. Whether the Regional Trial Court (RTC) had jurisdiction over LRC Case No. 421 for the reconstitution of title.
Ruling
The petition is meritorious. The Resolutions dated March 13, 2015 and October 9, 2015 of the Court of Appeals (CA) in CA-G.R. SP No. 136564 are REVERSED and SET ASIDE. The case is REMANDED to the CA for further proceedings.
Ratio Decidendi
On the issue of whether the CA correctly denied due course to Sebastian's petition for annulment of judgment and dismissed it outright: The CA erred in dismissing Sebastian's petition for annulment of judgment outright. Under Section 2, Rule 47 of the Rules of Court, lack of jurisdiction is a valid ground for annulment of judgment. A judgment rendered without jurisdiction is void and has no legal effect. The CA should have given due course to the petition to determine the jurisdictional issue. On the issue of whether the RTC had jurisdiction over LRC Case No. 421 for the reconstitution of title: The fact of loss or destruction of the owner's duplicate certificate of title is crucial for the RTC to acquire jurisdiction over judicial reconstitution proceedings. If the owner's duplicate certificate of title was not actually lost but is in the possession of another person, the reconstituted title is void because the court that rendered the order of reconstitution had no jurisdiction over the subject matter. Sebastian's allegation that the owner's duplicate copy of OCT No. P-41566 was not lost and was in her possession, contrary to Spouses Cruz's claim, raises a jurisdictional issue that must be resolved. If proven, the RTC decision in LRC Case No. 421 would be void for lack of jurisdiction.
Main Doctrine
A reconstituted title is void if the owner's duplicate certificate of title was not actually lost but is in the possession of another person, as the court that rendered the order of reconstitution lacked jurisdiction over the subject matter.