GR 161042; (August, 2009) (Digest)
G.R. No. 161042; August 24, 2009
REPUBLIC OF THE PHILIPPINES, Petitioner, vs. AGRIPINA DELA RAGA, Respondent.
FACTS
Respondent Agripina Dela Raga, claiming to be the granddaughter and sole heir of spouses Ignacio Serran and Catalina Laguit, filed a petition for the judicial reconstitution of Original Certificate of Title (OCT) No. 49266 covering a 79,570-square meter parcel of land in Sison, Pangasinan. Dela Raga asserted that the owner’s duplicate copy of the title was lost and that the copy in the custody of the Register of Deeds was also destroyed or lost, as confirmed by a certification from the registry. She based her petition on Decree No. 196266, which she discovered in the Register of Deeds of Manila, showing the property was originally registered in the names of Ignacio, Laguit, and spouses Felipe Serafica and Cornelia Serran.
The Regional Trial Court (RTC) granted the petition after finding that Dela Raga had sufficiently proven her relationship to the registered owners, the existence and subsequent loss of OCT No. 49266, and her compliance with all jurisdictional requirements for reconstitution, including publication and notice. The Court of Appeals affirmed the RTC decision in toto. The Republic of the Philippines, through the Office of the Solicitor General, elevated the case to the Supreme Court, arguing that the reconstitution was improper due to alleged insufficiency of evidence and non-compliance with mandatory procedures.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s decision granting the petition for judicial reconstitution of the lost OCT.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court emphasized that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive. The Republic failed to demonstrate that the case fell under any recognized exception to this rule, such as a showing that the findings were grounded on speculation, constituted a misapprehension of facts, or lacked evidentiary support.
On the merits, the Court upheld the reconstitution, ruling that Dela Raga had presented competent and sufficient evidence to warrant the relief. This evidence included the certification from the Register of Deeds confirming the loss of the office copy, Decree No. 196266 as the basis for the original issuance of the title, and testimonial and documentary proof of her heirship and continuous possession. The Court cited Republic v. Casimiro, which holds that once a court finds the evidence sufficient and the jurisdictional requirements complied with, it becomes its mandatory duty to issue the order of reconstitution. The law does not grant discretion to deny reconstitution when all basic requirements have been satisfied. Consequently, the RTC and the Court of Appeals committed no reversible error in granting the petition.