GR 150741; (June, 2008) (Digest)
G.R. No. 150741 ; June 12, 2008
Republic of the Philippines, petitioner, vs. Sps. Vicente Lagramada and Bonifacia Lagramada, respondents.
FACTS
Respondents, spouses Vicente and Bonifacia Lagramada, filed a petition for reconstitution of the original and owner’s duplicate copies of Transfer Certificate of Title (TCT) No. 118717, covering a parcel of land in Quezon City. They alleged that the original copy on file with the Register of Deeds was destroyed in a 1988 fire, and the owner’s duplicate copy was misplaced by the registered owner, Reynaldo Pangilinan, from whom they purchased the property in 1996. The trial court granted the petition based on submitted documents, including a certification of the title’s destruction, an affidavit of loss, the deed of sale, tax receipts, a tax declaration, and a survey plan with technical description. The Court of Appeals affirmed the decision.
ISSUE
Whether the documents presented by the respondents constitute sufficient bases for the reconstitution of TCT No. 118717 under Republic Act No. 26.
RULING
No. The Supreme Court granted the petition and set aside the lower courts’ decisions, dismissing the petition for reconstitution. The legal logic centers on the strict interpretation of the sources for reconstitution under Sections 2 and 3 of R.A. No. 26. For reconstituting a transfer certificate of title, the law enumerates a hierarchy of sources. The respondents relied on the catch-all provision of “any other document” under Section 3(f), which requires that such a document be, in the court’s judgment, a sufficient and proper basis, and must be accompanied by a plan and technical description approved by the Land Registration Authority (LRA).
The Court found the respondents’ evidence fatally insufficient. The deed of absolute sale is an unregistered private document that does not conclusively prove Pangilinan’s ownership. The tax declaration and receipts are merely indicia of a claim of ownership but are not conclusive evidence of title. Crucially, the submitted survey plan and technical description were defective. The plan was prepared for one of the respondents after the petition was filed, and the officials who verified and certified these documents were not presented as witnesses to authenticate them. The Court emphasized the duty of courts to exercise extreme caution in reconstitution proceedings to prevent the proliferation of fake titles. The failure to present the alleged owner, Pangilinan, and the lack of authentic, contemporaneous official records tracing the title’s origin meant the respondents did not meet the stringent evidentiary standards required by law for reconstitution.