GR 146081; (July, 2006) (Digest)
G.R. No. 146081 ; July 17, 2006
Republic of the Philippines, Represented by the Land Registration Authority, petitioner, vs. Spouses Roberto and Marina Sanchez, respondents.
FACTS
Respondents filed a petition for reconstitution of the original copy of TCT No. 252708, which was allegedly destroyed in a 1988 fire, based on the owner’s duplicate certificate of title. The trial court granted the petition after considering a Report from the Land Registration Authority (LRA), which stated that the technical description of the property did not overlap with other titles. The reconstitution order became final, and a new title was issued.
Subsequently, the LRA submitted a Second Report to the trial court, declaring the First Report as fake and recommending the setting aside of the reconstitution order. The LRA alleged that the property was already covered by other valid and existing certificates of title in the names of different persons. The trial court denied the LRA’s motion to set aside its order, ruling it had lost jurisdiction as its order was final. The Court of Appeals affirmed the trial court.
ISSUE
Whether the trial court’s final and executory reconstitution order can be set aside on the ground of extrinsic fraud and lack of jurisdiction.
RULING
Yes. The Supreme Court reversed the Court of Appeals and set aside the reconstitution order. The Court ruled that the trial court never acquired jurisdiction over the petition for reconstitution because of the petitioners’ failure to comply with the mandatory requirements of Republic Act No. 26. Specifically, the notice of hearing was not published in a newspaper of general circulation as required by law, which is a jurisdictional defect. A judgment rendered by a court without jurisdiction is void and can be attacked at any time.
Furthermore, the Court found extrinsic fraud, which prevented the LRA from fully presenting its case. The submission of a fake LRA Report constituted fraud, as it misled the court regarding the status of the title and the existence of other titles covering the same property. Extrinsic fraud is a valid ground for annulling a final judgment, as it deprives a party of the opportunity to be heard. The LRA’s subsequent discovery of the fraud and the existence of other valid titles warranted the reopening of the case to prevent a gross miscarriage of justice. The reconstitution proceedings were declared void ab initio.