G.R. No. 142549. March 9, 2010
FIDELA R. ANGELES, Petitioner, vs. The SECRETARY OF JUSTICE, THE ADMINISTRATOR, LAND REGISTRATION AUTHORITY, THE REGISTER OF DEEDS OF QUEZON CITY, and SENATOR TEOFISTO T. GUINGONA, JR., Respondents.

FACTS

Petitioner Fidela R. Angeles, along with other alleged heirs of Maria de la Concepcion Vidal, filed a special civil action for partition and accounting of the Maysilo Estate covered by Original Certificate of Title (OCT) No. 994. This was docketed as Civil Case No. C-424 in the Regional Trial Court (RTC) of Caloocan City. On January 8, 1998, the RTC issued an Order granting the partition and directing the Registers of Deeds of Caloocan City and Quezon City to issue Transfer Certificates of Title (TCTs) in the names of the co-owners, including petitioner, for specific parcels of land, and ordered the sale of said properties. The Order became final on March 12, 1998.
The Registers of Deeds refused to comply with the RTC Order, awaiting instruction from the Land Registration Authority (LRA) Administrator. The LRA Administrator, in a letter-reply dated March 27, 2000, cited a Department of Justice (DOJ) 1st Indorsement dated September 22, 1997, issued by then Secretary Teofisto T. Guingona, Jr., which directed that OCT No. 994 was issued only on May 3, 1917 (not April 19, 1917), based on a fact-finding committee report. The LRA also issued Circular No. 97-11 to all Registers of Deeds in line with this directive. The LRA Administrator argued that compliance with the RTC Order would result in duplicate titles, as OCT No. 994 had long been cancelled, and the parcels were already covered by existing TCTs. Petitioner filed a petition for mandamus to compel respondents to comply with the RTC Order, alleging that the DOJ and LRA actions constituted a substantive modification of final Supreme Court rulings (e.g., MWSS v. Court of Appeals and Heirs of Luis J. Gonzaga v. Court of Appeals) and usurped judicial functions.

ISSUE

Whether the respondents, particularly the Secretary of Justice and the LRA Administrator, may refuse to comply with a final and executory RTC Order directing the issuance of TCTs based on their own findings regarding the validity of OCT No. 994, and whether mandamus lies to compel such compliance.

RULING

The Supreme Court DENIED the petition for mandamus. The Court held that mandamus is not proper to compel the performance of an act that is not ministerial. The issuance of TCTs by the Registers of Deeds, as directed by the RTC Order, is not a purely ministerial duty if there are valid legal grounds for refusal, such as the existence of prior titles or irregularities in the registration process. The LRA Administrator and the Registers of Deeds have a statutory duty under the Property Registration Decree to ensure the integrity of the Torrens system and prevent the issuance of overlapping or fraudulent titles. The Court affirmed that OCT No. 994 was issued only on May 3, 1917, as established in Manotok Realty, Inc. v. CLT Realty Development Corporation, and that titles derived from a non-existent April 19, 1917 date are void. The RTC Order in Civil Case No. C-424 was based on a fabricated version of OCT No. 994 and could not override existing valid titles. Thus, respondents were justified in refusing compliance, and mandamus did not lie to enforce a void or irregular order.