G.R. No. 127969 June 25, 1999
Republic of the Philippines, represented by the Land Registration Authority, petitioner, vs. The Honorable Court of Appeals, Jose M. Estrada and The Register of Deeds of the Province of Cavite, respondents.

FACTS

Jose M. Estrada filed a petition for the judicial reconstitution of the lost/burned original copies of Transfer Certificates of Title (TCT) Nos. T-11203 and T-11204 with the Regional Trial Court (RTC) of Imus, Cavite. He alleged the titles were destroyed in a fire at the capitol building. After publication and hearing, where Estrada presented testimonial and documentary evidence including alleged owner’s duplicates and tax declarations, and with no opposition interposed, the RTC granted the petition. The court ordered the Register of Deeds of Cavite to effect the reconstitution.
The Register of Deeds, Atty. Alejandro Villanueva, refused to comply, casting doubt on the authenticity of the presented documents. He explained that a certification from the Provincial Assessor indicated the tax declarations were not genuine and, critically, that the land was already covered by a valid existing title (TCT No. T-26877) issued in 1967 in the name of Pilar Development Co., Inc. The RTC cited him for contempt and ordered his incarceration. The Court of Appeals affirmed the RTC’s reconstitution order and the contempt charge.

ISSUE

Whether the RTC acquired jurisdiction over the petition for judicial reconstitution.

RULING

No, the RTC did not acquire jurisdiction. The Supreme Court granted the Republic’s petition, reversed the Court of Appeals, and declared the RTC’s decision and orders null and void. Jurisdiction in judicial reconstitution cases under Republic Act No. 26 is not automatically conferred by the mere filing of a petition. The court must first ascertain that the petition falls under the specific sources enumerated in Section 2 of the law and, under Section 3, that the certificate of title had not been previously cancelled. The existence of a prior valid title, TCT No. T-26877 issued to another entity in 1967, was a fatal jurisdictional defect. This prior title meant the titles sought to be reconstituted (TCT Nos. T-11203 and T-11204) had already been cancelled and were no longer in force. Consequently, the petition was not among those authorized by law, rendering the RTC without jurisdiction from the outset. A judgment rendered without jurisdiction is void and produces no legal effect. The Register of Deeds was correct in challenging the reconstitution, and the contempt order against him was invalid.