Gaoiran v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Esperanza P. Gaoiran alleged that she was induced by Timoteo H. Pablo, Jr. to purchase a parcel of land for P500,000.00, which was registered under the name of Timoteo's wife, respondent Perlita S. Pablo. Timoteo surrendered the owner's duplicate copy of Transfer Certificate of Title No. (TCT) T-34540 to petitioner, promising to deliver a deed of absolute sale signed by his wife. Timoteo failed to deliver the deed and did not return the purchase price, prompting petitioner to file an Estafa case against him. Procedural History: Following the Estafa complaint, petitioner attempted to annotate an adverse claim on TCT T-34540 but was informed by the Register of Deeds that it was not possible for a criminal complaint. Meanwhile, respondent Mary Nyre Dawn Alcantara, claiming to be Perlita's niece and trustee, filed a petition for the issuance of a new owner's duplicate copy of TCT T-34540, alleging the original was lost. The Regional Trial Court (RTC) of Laoag City, Branch 12, granted this petition. Subsequently, petitioner filed a petition for annulment of judgment with the Court of Appeals (CA), seeking to nullify the RTC's decision, arguing it was obtained through extrinsic fraud and lack of jurisdiction because the original title was not lost and was in her possession. The CA dismissed this petition, ruling that it constituted a collateral attack on the reconstituted title. The Petition: Petitioner Esperanza P. Gaoiran filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to reverse the CA's dismissal of her petition for annulment of judgment. She contends that the CA committed grave abuse of discretion by not annulling the RTC's decision, which she argues was void for lack of jurisdiction since the owner's duplicate copy of TCT T-34540 was never lost but was in her possession. The petition argues that the RTC lacked jurisdiction to issue a new title when the original was not lost, making the reconstituted title void. The Supreme Court, while noting the procedural impropriety of a Rule 65 petition, gave due course to the petition in the interest of justice and found that the CA erred in dismissing the annulment petition.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for annulment of judgment, considering the propriety of the remedy availed of by the petitioner. Whether the RTC of Laoag City had jurisdiction to issue a second owner's duplicate copy of TCT T-34540, considering the alleged loss of the first owner's duplicate copy and the nature of reconstitution proceedings. Whether the petition for annulment of judgment before the CA constituted a collateral attack on the reconstituted title, and the distinction from Sps. Lim.
Ruling
The petition is meritorious. The Supreme Court reversed and set aside the Decision and Resolution of the Court of Appeals, and annulled the Decision of the RTC of Laoag City, Branch 12, declaring the new owner's duplicate certificate of title issued pursuant to the RTC's proceedings as void. SO ORDERED.
Ratio Decidendi
On the propriety of the remedy: The Court acknowledged that petitioner availed of the wrong mode of appeal by filing a petition for certiorari under Rule 65 instead of a petition for review on certiorari under Rule 45 to assail the CA's decision. However, in the interest of justice and to prevent further prolonging the proceedings, the Court resolved to give due course to the petition and rule on the merits, citing its discretion to relax rigid application of procedural rules when the ends of justice would be better served. This demonstrates the Court's commitment to substantive justice over strict adherence to procedural technicalities in exceptional circumstances. On the jurisdiction of the RTC and the nature of reconstitution proceedings: The Court held that lack of jurisdiction as a ground for annulment of judgment refers to the absence of jurisdiction over the person or the subject matter. A judgment rendered without jurisdiction is void and has no legal effect. The fact of loss or destruction of the owner's duplicate certificate of title is crucial in clothing the RTC with jurisdiction over judicial reconstitution proceedings. If the certificate of title has not been lost but is in the possession of another person, the reconstituted title is void, and the court that rendered the decision had no jurisdiction. This principle underscores the fundamental requirement of a genuine loss or destruction for a court to validly exercise its power in reconstitution cases. The Court reiterated that the reconstitution of a title is merely the re-issuance of a lost or destroyed duplicate certificate in its original form and condition. It does not determine or resolve ownership. The purpose is to restore the title to its original state after loss or destruction. Therefore, if there was no actual loss or destruction, there is nothing to reconstitute, and any order for reconstitution would be based on a false premise. The Court found that petitioner clearly alleged in her petition before the CA that the owner's duplicate copy of TCT T-34540 was not lost, but was in her possession since September 2009, having been surrendered to her by Timoteo. This fact, if proven, would divest the RTC of jurisdiction. The Court noted that the allegedly lost TCT was offered in evidence by the petitioner before the CA, and the respondents did not contest its genuineness and authenticity. This evidence directly challenges the premise of the RTC's jurisdiction. On collateral attack and distinction from Sps. Lim: The Court clarified that the petition for annulment of judgment was not a collateral attack on TCT T-34540. Instead, it was a direct challenge to the RTC Decision that granted the reconstitution. The petitioner only needed to show that the owner's duplicate copy was not lost to establish the RTC's lack of jurisdiction, which would render the subsequent decision void. The annulment of the RTC decision would then be a necessary consequence, leading to the cancellation of the reconstituted title. The Court distinguished the present case from Heirs of the Late Sps. Luciano P. Lim v. The Presiding Judge of the Regional Trial Court of Quezon City. In Sps. Lim, the petitioners were not real parties-in-interest because the property they claimed was different from the property covered by the reconstituted title. In the instant case, the property covered by the reconstituted title is the same property that petitioner claimed to possess. Furthermore, in Sps. Lim, the parties were directly impugning their respective titles and raising issues of ownership, necessitating a direct proceeding. Here, the petitioner's primary aim was to annul the RTC Decision for lack of jurisdiction, not to collaterally attack the title itself, but to show that the RTC had no authority to issue a new title.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Court may be availed of to annul a decision granting the reconstitution of a title if the owner's duplicate certificate of title was not lost but was in fact in the possession of another person, as this renders the RTC decision void for lack of jurisdiction.