Young v. Registrador de Titulos de Manila
REITERATIONFacts
The Antecedents: Carlos Young mortgaged two parcels of land to 'The Roman Catholic Archbishop of Manila' in 1932. Subsequently, Young subdivided these two parcels into 313 smaller lots. The mortgage credit was later assigned to the Banco de las Islas Filipinas. In 1939, two separate deeds of cancellation of mortgage were executed: one by the Banco de las Islas Filipinas and another by 'The Roman Catholic Archbishop of Manila' for the original mortgage. Procedural History: The Registrar of Titles of Manila demanded payment of P313 for each cancellation deed, totaling P626, in addition to presentation fees, for the registration of these two cancellation documents. Carlos Young appealed this assessment, arguing that the fees were excessive. The Appeal: Carlos Young appealed the resolution of the Court of First Instance of Manila, which upheld the Registrar's right to collect P313 for each cancellation deed. Young contended that the Registrar erred in demanding these fees, arguing that the fees should not be based on the number of subdivided lots but on the documents themselves. He also argued that the fees were exorbitant.
Issue(s)
Whether the Registrar of Titles is entitled to collect P313 for each of the two deeds of cancellation of mortgage, in addition to presentation fees, when the original mortgaged properties had been subdivided into 313 lots. Whether the Court of First Instance erred in upholding the Registrar's assessment of fees.
Ruling
The Supreme Court affirmed the resolution of the Court of First Instance of Manila and the assessment of the Registrar of Titles. The Court ruled that the Registrar has the right to collect P313 for each cancellation deed, totaling P626, plus presentation fees, because the original mortgaged properties were subdivided into 313 distinct parcels of land. The Court dismissed the appeal for lack of merit.
Ratio Decidendi
On Issue 1: The Court held that the Registrar of Titles correctly assessed the fees for the cancellation of the mortgages. According to Section 114 of Act No. 496, as amended by Act No. 2866, the fees for cancellation of a mortgage are calculated 'por cada finca' (for each parcel of land). In this case, the original two parcels of land had been subdivided into 313 distinct lots. Therefore, each of these 313 lots was considered a separate 'finca' that would be freed from the mortgage encumbrance upon registration of the cancellation deeds. The Court emphasized that the basis for the fee is not the mechanical act of annotation but the number of distinct properties liberated from the mortgage. Thus, for two cancellation deeds affecting 313 distinct lots, the Registrar was justified in collecting fees corresponding to the number of affected parcels. On Issue 2: The Court found no error in the resolution of the Court of First Instance of Manila, which upheld the Registrar's assessment. The lower court's decision was based on the same principle that the fees are determined by the number of distinct parcels of land affected by the registration. The subdivision of the original mortgaged properties fundamentally altered the nature, extent, and number of the parcels. Consequently, the Registrar's demand for fees corresponding to each of the 313 lots, as represented by the two cancellation deeds, was in accordance with the law. The appeal was therefore dismissed as lacking merit.
Main Doctrine
The Supreme Court affirmed the Registrar of Titles' right to collect registration fees based on the number of distinct parcels of land affected by a mortgage cancellation, even if multiple parcels originated from a single original title. The Court clarified that the basis for the fee is the number of 'fincas' (parcels of land) that become free from the mortgage encumbrance, as provided by law, and not solely the number of cancellation documents presented. This interpretation was based on the subdivision of the original mortgaged properties into numerous lots, each considered a distinct entity for registration purposes.