G.R. No. 184589; June 13, 2013
DEOGENES O. RODRIGUEZ, Petitioner, vs. HON. COURT OF APPEALS and PHILIPPINE CHINESE CHARITABLE ASSOCIATION, INC., Respondents.

FACTS

Purita Landicho filed an application for registration of a 125-hectare land in San Mateo, Rizal in 1965. The Court of First Instance (CFI) granted her application in a 1965 Decision, finding she and her predecessors-in-interest had possessed the land since 1930 and that the land was alienable and disposable. The decision became final, and the CFI ordered the issuance of a decree and title. However, the Register of Deeds (ROD) issued Transfer Certificate of Title (TCT) No. 167681 to Landicho in 1966 instead of an Original Certificate of Title (OCT). The property was subsequently sold several times, ultimately ending up with respondent Philippine Chinese Charitable Association, Inc. (PCCAI) in 1975. In 1996, Landicho executed a deed of absolute sale over the same property in favor of petitioner Deogenes Rodriguez. In 2005, Rodriguez filed an Omnibus Motion in the original land registration case, seeking to compel the Land Registration Authority (LRA) to issue the decree and direct the ROD to issue an OCT, arguing the 1966 TCT was void for being issued without a prior decree.

ISSUE

Whether the Regional Trial Court (RTC) gravely abused its discretion in granting Rodriguez’s motion to compel the issuance of a decree and an OCT, despite the finality of the 1965 judgment and the subsequent issuance of a TCT.

RULING

No. The Supreme Court affirmed the Court of Appeals’ ruling that the RTC committed grave abuse of discretion. The legal logic is anchored on the doctrine of finality of judgment and the specific statutory procedure for land registration. A judgment in a land registration case becomes final and executory after the period to appeal lapses. The court’s ministerial duty thereafter is to issue an order for the LRA Commissioner to prepare the decree, and for the ROD to issue the corresponding OCT. In this case, the CFI performed this duty by issuing the 1965 Order directing the LRA Commissioner to issue the decree. The subsequent act of the ROD in issuing a TCT in 1966, while irregular, did not nullify the final judgment. The proper remedy for Rodriguez was not to reopen the concluded registration case but to pursue an ordinary civil action to question the validity of the TCT and the titles derived from it. The RTC, in granting the Omnibus Motion, effectively altered the final judgment and assumed jurisdiction over a collateral attack on PCCAI’s title, which is prohibited. The title of PCCAI, as an innocent purchaser for value, is protected by law. Thus, the RTC’s orders were issued without jurisdiction and with grave abuse of discretion.