Heirs of Ramirez v. Abon
MODIFICATIONFacts
The Antecedents: The underlying dispute concerns Original Certificate of Title No. T-4480, registered in the names of the late Spouses Gervacio Ramirez and Martina Carbonel, covering a 1,266-square meter lot. In 1978, Angel Abon, father of respondent Joey Abon, requested a new owner's duplicate of the title based on a "Confirmation of Previous Sale" (CPS) allegedly executed by the Spouses Ramirez. Using this new duplicate, Angel Abon segregated a 135-square meter portion, obtaining Transfer Certificate of Title No. T-50359. The petitioners, Heirs of Spouses Ramirez, learned of the CPS in 2013 and, fearing respondent Abon would use it to claim the rest of the lot, sought to annul the CPS due to forgery. Procedural History: The petitioners' initial complaint for annulment of the CPS was dismissed by the Regional Trial Court (RTC) of Nueva Vizcaya, Branch 27, for lack of jurisdiction. Their subsequent certiorari petition to the Court of Appeals (CA), Fourth Division, was denied, and the denial became final. Meanwhile, respondent Abon filed a petition for reconstitution of the lost owner's duplicate of OCT No. 4480 with the RTC, Branch 28, alleging his father acquired the lot via the CPS and that the owner's duplicate was lost. The RTC, Branch 28, granted this petition, ordering the issuance of a new owner's duplicate. This decision became final and executory as it was not appealed. Subsequently, the petitioners filed a Petition for Annulment of Judgment before the CA, Former Fourteenth Division, assailing the RTC, Branch 28's decision. The Petition: The petitioners, Heirs of Spouses Ramirez, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's denial of their Petition for Annulment of Judgment. They argue that the RTC, Branch 28, abused its discretion and lacked jurisdiction in granting respondent Abon's petition for reconstitution. Their primary contention is that they, as successors-in-interest of the registered owners, were not notified of the reconstitution proceedings, violating their due process rights. They assert that the registered owners, their predecessors-in-interest, should have been notified as they remain interested parties, regardless of the alleged sale, as the OCT is still registered in their names.
Issue(s)
Whether the Court of Appeals erred in denying the Petition for Annulment of Judgment. Whether the Regional Trial Court, Branch 28, acquired jurisdiction over the Petition for Reconstitution of a lost owner's duplicate certificate of title.
Ruling
The Supreme Court granted the petition, reversed and set aside the Court of Appeals' Decision and Resolution, and annulled the Regional Trial Court, Branch 28's Decision dated October 4, 2013, without prejudice to the refiling of another petition for reconstitution with proper notice to all interested parties.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in denying the Petition for Annulment of Judgment: The Court finds the petition meritorious. A petition for annulment of judgment under Rule 47 of the Rules of Court is available when ordinary remedies are no longer available and is based on extrinsic fraud or lack of jurisdiction or denial of due process. The petitioners' core argument is that the RTC, Branch 28, lacked jurisdiction over the petition for reconstitution because they, as successors-in-interest of the registered owners, were not notified. The Court agrees that the failure to notify the registered owners constitutes a violation of due process and deprives the RTC of jurisdiction. On the issue of whether the Regional Trial Court, Branch 28, acquired jurisdiction over the Petition for Reconstitution of a lost owner's duplicate certificate of title: The Court holds that the RTC, Branch 28, failed to acquire jurisdiction. The applicable law for the replacement of a lost owner's duplicate certificate of title is Section 109 of Presidential Decree (PD) No. 1529, not Republic Act (RA) No. 26, which pertains to the reconstitution of lost original certificates of title. Section 109 of PD 1529 requires notice and due hearing. While respondent Abon sent notice to the Register of Deeds and posted copies of the petition, it is undisputed that the registered owners, Sps. Ramirez, and their successors-in-interest, the petitioners, were not notified. The Court emphasizes that the registered owner is an interested party in a petition for reconstitution because they are presumed to be the owners and possess a preferential right to the owner's duplicate certificate. Failure to notify them violates their due process rights and prevents the court from acquiring jurisdiction. The Court clarified that its ruling in Office of the Court Administrator v. Judge Matas does not exclude the registered owner as an interested party; rather, it pertains to alleged interested parties whose interests are not registered or inscribed on the certificate of title.
Main Doctrine
A court fails to acquire jurisdiction over a petition for reconstitution of a lost owner's duplicate certificate of title if it fails to notify the registered owner(s) of the property, as they are considered interested parties whose due process rights must be safeguarded.