Republic v. Lamaclamac
REITERATIONFacts
The Antecedents: The Republic of the Philippines, represented by the Department of Transportation (DOTr), filed a Complaint for Cancellation of Decree against Guillerma Lamaclamac and the Land Registration Authority (LRA). The subject of the complaint was Lot No. 12446, Cadastral No. 27, for which Decree No. 756523 was issued in favor of Lamaclamac on August 26, 1941. Lamaclamac died in 1947, and her heirs later sold the lot to the government, which is now using it for the Laguindingan Airport Development Project. Procedural History: The DOTr filed the complaint based on certifications from the LRA and the Registrar of Deeds (RD) of Misamis Oriental stating that Decree No. 756523 was not among the salvaged decrees and was presumed lost or destroyed due to World War II. The DOTr argued that Lamaclamac's failure to secure a certificate of title for over 65 years constituted abandonment and laches. The Regional Trial Court (RTC) dismissed the complaint for insufficiency of evidence, finding that the DOTr failed to prove Lamaclamac did not secure a title, as a decree was issued, making title issuance a ministerial duty. The RTC also ruled that Lamaclamac was not guilty of laches. The Court of Appeals (CA) affirmed the RTC's decision. The Petition: The Republic, through the Office of the Solicitor General (OSG), filed a Petition for Review on Certiorari, asserting that the CA erred in affirming the RTC's denial of the complaint, as there was no evidence that the decree was transcribed in the registry books or that a certificate of title was issued. The OSG argued that the absence of the decree indicated no final adjudication of title, justifying cancellation.
Issue(s)
Whether the Court of Appeals gravely erred in affirming the RTC decision denying the complaint for cancellation of decree considering the absence of evidence to prove that the decree issued to private respondent had actually been transcribed in the registry books of the Register of Deeds. Whether the failure to secure a certificate of title after more than 65 years from the issuance of the decree constitutes abandonment and laches.
Ruling
The petition is bereft of merit. The Supreme Court denied the Petition for Review on Certiorari, affirmed the Decision of the Court of Appeals, and dismissed the Complaint for Cancellation of Decree.
Ratio Decidendi
On the issue of whether the CA gravely erred in affirming the RTC decision denying the complaint for cancellation of decree considering the absence of evidence to prove that the decree issued to private respondent had actually been transcribed in the registry books of the Register of Deeds: The Supreme Court held that a land becomes registered land once the decision of the cadastral court declaring the adjudicatee as owner attains finality. The issuance of a decree of registration is a judicial act, and its finality vests ownership upon the adjudicatee. The subsequent issuance of the certificate of title by the Land Registration Authority (LRA) is a ministerial duty. The Court emphasized that the absence of records or the loss of the decree due to war does not negate the vested ownership. The LRA and RD certifications did not categorically state that no title was issued; instead, they implied that the original might have been lost or destroyed during World War II, even recommending reconstitution. The Court reiterated that proceedings for land registration are presumed to have been regularly and properly conducted, and it would be unjust to prejudice parties due to the scarcity of government records, especially after a significant lapse of time. The presumption of regularity in the performance of official functions applies, and overturning this presumption without countervailing proof would undermine the Torrens system. On the issue of whether the failure to secure a certificate of title after more than 65 years from the issuance of the decree constitutes abandonment and laches: The Supreme Court ruled that laches and prescription do not apply to decisions in land registration cases. Land registration is a special proceeding aimed at establishing ownership by judicial fiat. Once a decision becomes final, it is complete and declaratory in character, requiring no further enforcement against an adverse party unless the losing party is in possession. The Court clarified that after the decree of registration attains finality, no further step is required from the adjudicatee to effectuate the decision, as the duty to issue the certificate of title devolves upon the government agencies. The failure of these administrative authorities to perform their ministerial duty cannot divest the prevailing party of ownership. Therefore, inaction on the part of the adjudicatee, especially when the delay is attributable to the government's failure to issue the title or the loss of records, cannot be construed as abandonment or laches. The Court cited numerous cases affirming the doctrine that neither prescription nor laches may render inefficacious a decision in a land registration case.
Main Doctrine
The issuance of a decree of registration in a cadastral proceeding vests ownership upon the adjudicatee, and the subsequent failure of administrative agencies to issue the corresponding certificate of title, or the loss of records due to war, does not divest the owner of their vested rights, nor does it give rise to laches or prescription against them, as the issuance of the title becomes a ministerial duty of the government.