DMCI Project Developers, Inc. v. Bernadas
REITERATIONFacts
The Antecedents: A parcel of land, covered by TCT No. 25491, became the subject of a labor case filed by Nelia Bernadas, et al. (Bernadas et al.) against Liberty Transport Corp. and/or Mr. and Mrs. Honorato Lacsina. The National Labor Relations Commission (NLRC) ruled in favor of Bernadas et al., leading to a Notice of Levy annotated on TCT No. 25491. An auction sale was conducted, and Bernadas et al. emerged as the winning bidder. Subsequently, Bernadas et al. executed a Deed of Sale and/or Certificate of Redemption of Real Property and a Release and Quitclaim, ceding ownership of the subject lot to DMCI Project Developers, Inc. (DMCI) for P1,915,800.00. DMCI and Bernadas et al. then filed a petition to cancel the levy and certificate of sale. Taguig Land Development Corporation (Taguig Land) acquired the lot and later merged with DMCI. Procedural History: Bernadas et al. later filed a motion before the NLRC to nullify the Deed of Sale and/or Certificate of Redemption and Release and Quitclaim, alleging they were spurious and falsified. They claimed they were made to sign documents believing they were receipts for P100,000.00, not the full P1,915,800.00 award. The Labor Arbiter (LA) granted the motion, nullifying the documents and ordering the cancellation of TCT No. 12619 in favor of Bernadas et al. The NLRC affirmed the LA's order. DMCI appealed to the Land Registration Authority (LRA) via consulta, questioning the NLRC's power to order cancellation of title and whether the order covered shares of previous owners not party to the labor case. The LRA ruled that the NLRC order and its entry of judgment were registrable. DMCI's motion for reconsideration was denied. DMCI then filed a petition for review with the Court of Appeals (CA), which affirmed the LRA's resolution. DMCI's motion for reconsideration was denied, leading to the present petition before the Supreme Court. The Petition: DMCI assails the CA's affirmation of the LRA's resolution, arguing that the LA's order cannot be implemented or registered without a writ of execution. DMCI also claims the CA disregarded a subsequent LA order denying a motion for execution in the original labor case and overlooked DMCI's pending complaint for quieting of title with the Regional Trial Court (RTC).
Issue(s)
Whether the Court of Appeals gravely erred in sustaining the Resolution dated April 3, 2013 and the Order dated September 26, 2013 of the Land Registration Authority. Whether the January 4, 2011 Order of the Labor Arbiter can be implemented or registered in the absence of a writ of execution. Whether the Court of Appeals gravely erred in disregarding a subsequent order from the Labor Arbiter denying a motion for execution in the original labor case. Whether the Court of Appeals overlooked the existence and relevance of DMCI's complaint for quieting of title filed with the RTC.
Ruling
The Supreme Court denied the petition. It affirmed the Court of Appeals' decision, which upheld the Land Registration Authority's resolution and order. The Court found that the January 4, 2011 Order of the Labor Arbiter, along with the Entry of Judgment, was registrable. The Court emphasized that the LRA's declaration of registrability is distinct from actual registration, which is a ministerial duty of the Register of Deeds. Furthermore, the Court held that the immutability of the final and executory judgment, evidenced by the Entry of Judgment dated May 16, 2012, precluded further challenge, especially on grounds that were already settled or could have been raised in prior appeals. The Court also noted DMCI's procedural misstep in belatedly filing its appeal with the Court of Appeals.
Ratio Decidendi
On the registrability of the NLRC Order and the necessity of a writ of execution: The Court held that the LRA's role in a consulta is to determine the registrability of an instrument or order, not to effect the actual registration. The actual registration is a ministerial duty of the Register of Deeds. The LRA merely declared the January 4, 2011 Order registrable, which is distinct from the cancellation of DMCI's title. The Court clarified that a writ of execution is indeed indispensable for enforcing NLRC decisions, but the consulta itself did not dispense with this requirement; it merely declared the order registrable. The Court emphasized that the Register of Deeds is bound by the LRA's ruling in a consulta, and its duty to register is ministerial once the consulta has become final and binding. On the implementation or registration of the January 4, 2011 Order in the absence of a writ of execution: The Court clarified that a writ of execution is indeed indispensable for enforcing NLRC decisions, but the consulta itself did not dispense with this requirement; it merely declared the order registrable. On the alleged disregard of a subsequent LA order denying a motion for execution: The Court found that the CA's decision was based on the supervening event of the NLRC's second Entry of Judgment dated May 16, 2012, which rendered the issue moot. The Court noted that the immutability of judgments doctrine applies, and parties cannot circumvent this by assailing the execution of a judgment. The Court also pointed out that DMCI's arguments regarding the merits of the case and ownership were issues that should have been properly addressed in the appeal, which DMCI failed to perfect within the reglementary period. On the relevance of the RTC case for quieting of title: The Court reiterated that DMCI's claim of ownership had already been dismissed with finality by the CA in a July 31, 2009 Decision. The subsequent filing of a quieting of title case did not alter the finality of the earlier judgment. The Court stressed that parties cannot indirectly attack a final and immutable judgment by raising issues related to its execution or by filing new actions that seek to relitigate settled matters.
Main Doctrine
The declaration of 'registrability' of a property by the Land Registration Authority (LRA) is distinct from the actual registration thereof. The LRA's role in a consulta is to determine whether an instrument or order is registrable, while the Register of Deeds performs the ministerial duty of inscribing it. Furthermore, the immutability of a final and executory judgment precludes its modification, even if assailed through an argument about the absence of a writ of execution, especially when the underlying claim has already been settled by prior final decisions.