G.R. No. 173120 & G.R. No. 173141, April 10, 2019
Case Parties/Title: Spouses Yu Hwa Ping and Mary Gaw, and Heirs of Spouses Andres Diaz and Josefa Mia, Petitioners, vs. Ayala Land, Inc., Respondent.

FACTS

This case involves a consolidated resolution on respondent Ayala Land, Inc.’s (ALI) Second Motion for Reconsideration against the Court’s July 26, 2017 Decision. In that Decision, the Court granted the petitions, reversed the Court of Appeals’ June 19, 2006 Decision, and reinstated the appellate court’s February 8, 2005 Amended Decision. ALI’s first Motion for Reconsideration, which included a motion to refer the case to the Court en banc, was denied with finality on December 4, 2017. ALI subsequently filed the instant Second Motion for Reconsideration, again with a motion for referral to the Court en banc, arguing that the July 26, 2017 Decision modified or reversed doctrines on land registration, prescription, and the Torrens System laid down by the Court en banc or in Division.

ISSUE

1. Whether the case should be referred to the Court en banc.
2. Whether ALI’s Second Motion for Reconsideration should be granted.

RULING

The Court denied both the referral to the Court en banc and the Second Motion for Reconsideration.
1. On the Referral to the Court En Banc: The Court held that the July 26, 2017 Decision neither modified nor reversed any doctrine or principle laid down by the Court en banc or a Division. It merely applied pertinent law and jurisprudence to the factual findings of the lower courts. The Supreme Court en banc is not an appellate court over its Divisions and exercises no appellate jurisdiction over them. Each Division sits as the Court en banc itself.
2. On the Second Motion for Reconsideration: The Court emphasized that Section 2, Rule 52 of the Rules of Court and Section 3, Rule 15 of the Internal Rules of the Supreme Court prohibit a second motion for reconsideration by the same party. Such a motion may only be entertained in the higher interest of justice if the assailed decision is not only legally erroneous but also patently unjust and capable of causing irremediable injury. ALI failed to assert any meritorious reason, as its arguments were mere reiterations of those raised in its Memorandum and First Motion for Reconsideration, with no novel issues presented.
3. Substantive Merits (Assumed for Argument’s Sake): The Court found that even if the substantive issues were entertained, the second motion lacked merit. It reiterated its core finding from the July 26, 2017 Decision: ALI’s titles are void because they are based on erroneous technical descriptions sourced from void ab initio surveys. The Court stressed that while a certificate of title is evidence of indefeasible title, it is not conclusive proof of ownership. A survey plan is indispensable in land registration as it establishes the exact identity of the property and prevents overlap. If the survey plan is erroneous, the technical description in the title is flawed, and the title itself is void. The Court cited Veterans Federation of the Philippines v. Court of Appeals, ruling that errors in the technical description cannot be disregarded as mere clerical errors and necessitate the title’s cancellation. The argument that ALI’s titles should be respected merely because they were issued earlier was rejected, as the validity of the underlying survey is paramount.