G.R. No. 185604; June 13, 2013
REPUBLIC OF THE PHILIPPINES, Petitioner, vs. EDWARD M. CAMACHO, Respondent.

FACTS

On March 6, 2003, respondent Edward M. Camacho filed a petition before the Regional Trial Court (RTC) of Villasis, Pangasinan, for the reconstitution of the original copy of an Original Certificate of Title (OCT) and the issuance of an owner’s duplicate copy. The OCT, whose number was no longer legible, was allegedly issued under Decree No. 444263 in the names of Spouses Nicasio Lapitan and Ana Doliente, covering two parcels of land in Pangasinan. Respondent claimed ownership by virtue of a Deed of Extra-Judicial Partition with Absolute Sale executed by the heirs of the Spouses Lapitan. He attached supporting documents, including a photocopy of the OCT, the deed, a tax declaration, and a Certification from the Register of Deeds stating the file copy was lost. The RTC found the petition sufficient and set it for hearing, ordering publication and posting. Respondent later filed a Second Amended Petition altering the stated boundaries of the property. During the hearing, respondent and adjoining landowners testified, and the Land Registration Authority (LRA) submitted a Report. The LRA Report indicated that Decree No. 444263 was issued on July 18, 1931, for a parcel of land in Alcala, Pangasinan, designated as Lot No. 1 of plan Psu-53673, containing 4,818 square meters, but noted that the technical description in the petition did not match the records. The RTC granted the petition. The Court of Appeals affirmed the RTC decision. The Republic of the Philippines appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the RTC decision granting the petition for reconstitution of the lost OCT.

RULING

The Supreme Court GRANTED the petition. The Court of Appeals’ decision was REVERSED and SET ASIDE. The petition for reconstitution was DISMISSED.
The Supreme Court held that the petition for reconstitution was fatally defective and the respondent failed to establish a sufficient basis for reconstitution. The ruling was based on the following:
1. Fatal Variance in Technical Descriptions: The LRA Report conclusively established that the technical description of the property in the petition (describing two lots, Lot No. 1 and Lot No. 2 of plan Psu-53673) did not match the official records. The Decree (No. 444263) on file with the LRA covered only one parcel of land (Lot No. 1 of plan Psu-53673) with an area of 4,818 square meters. The petition, however, sought to reconstitute a title for two lots with a combined area of 9,562 square meters. This discrepancy created doubt regarding the very existence and identity of the OCT sought to be reconstituted.
2. Failure to Comply with Mandatory Requirements of Republic Act No. 26: The petition was filed under RA 26, which governs judicial reconstitution of titles. The Court emphasized that reconstitution is a strict legal process aimed at re-establishing a lost or destroyed title in its original form and condition. The respondent’s failure to submit a plan and technical description duly approved by the LRA Commissioner, as required by Section 12 of RA 26, was a fatal omission. The LRA Report, which pointed out the discrepancies, was precisely the verification that the law requires to prevent the reconstitution of a fictitious or erroneous title.
3. Lack of Competent Source for the Reconstituted Title: The petition relied on the owner’s duplicate copy of the OCT. However, for an OCT (as opposed to a Transfer Certificate of Title), the sources for reconstitution are strictly limited under Section 2 of RA 26. The owner’s duplicate of an OCT is not among the enumerated sources. The only acceptable sources for reconstituting a lost OCT are the certificate of the LRA Commissioner or a certified copy of the description taken from a prior certificate of title. The respondent did not present any of these.
4. Contradictory Allegations and Procedural Infirmities: The Court noted the respondent’s filing of a Second Amended Petition that completely changed the boundaries of the property from those stated in the initial and first amended petitions. This serious inconsistency further undermined the credibility and certainty of the petition.
The Supreme Court concluded that the lower courts gravely erred in granting the reconstitution. The respondent failed to discharge the burden of proving the former existence of the title and presenting the mandatory documents required by law. Reconstitution cannot be used to establish ownership or to correct flaws in a title; it merely restores a lost or destroyed title. The petition was dismissed for lack of merit.