GR 162886; (August, 2008) (Digest)
G.R. No. 162886 ; August 11, 2008
HEIRS OF THE DECEASED SPOUSES VICENTE S. ARCILLA and JOSEFA ASUNCION ARCILLA, et al., petitioners, vs. MA. LOURDES A. TEODORO, respondent.
FACTS
Respondent Ma. Lourdes A. Teodoro filed an application for land registration over two parcels of land in Virac, Catanduanes. She claimed ownership by purchase from her father, Pacifico Arcilla, who allegedly acquired the lots through an extrajudicial settlement of his father’s estate. Petitioners, the heirs of Vicente Arcilla (Pacifico’s brother), opposed the application. They asserted ownership by inheritance from their father Vicente, who purportedly purchased the lots in 1917, and presented tax declarations to support their claim of possession since 1906. They moved to dismiss respondent’s application.
During the proceedings, respondent belatedly filed a motion to admit a verification and certificate against forum shopping, which she had initially omitted from her application. Petitioners moved to dismiss on this ground, arguing the certificate was a mandatory requirement. The Municipal Trial Court (MTC) denied the motion to dismiss and later granted respondent’s application for registration. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the MTC’s decision.
ISSUE
The primary issues were: (1) whether the belated filing of the certificate against forum shopping warranted dismissal of the application; and (2) whether the CA erred in affirming the lower courts’ findings on the ownership of the subject lots.
RULING
The Supreme Court denied the petition and affirmed the CA’s decision. On the procedural issue, the Court held that the belated submission of the certificate against forum shopping constituted substantial compliance. The requirement, while mandatory, is not jurisdictional. Dismissal is warranted only for a willful and deliberate defiance of the rule. The Court found respondent’s omission was due to oversight and inadvertence, not bad faith, and she rectified it upon discovery. The petitioners were not prejudiced, as they were able to fully participate in the trial.
On the substantive issue of ownership, the Court emphasized that in petitions for review under Rule 45, it is not a trier of facts. The factual findings of the trial courts, especially when affirmed by the CA, are generally conclusive and binding. The Court found no compelling reason to deviate from this rule, as the petitioners failed to demonstrate that the CA’s findings were grounded entirely on speculation or were in conflict with those of the trial courts. The lower courts’ evaluation of the evidence, which favored respondent’s claim of title, was thus upheld. The petition was bereft of merit.