G.R. No. 233578 , March 15, 2021
Republic of the Philippines, Petitioner, vs. Heirs of Julian Sta. Ana and Mercedes Sta. Ana, Respondents.

FACTS

Respondents Heirs of Julian Sta. Ana and Mercedes Sta. Ana filed an application for registration of Lot 459, Pasig Cadastre, docketed as LRC Case No. N-5999 before the RTC of Pasig City, Branch 155. They based their application on a final and executory Decision dated October 26, 1967, rendered in a prior registration case initiated by their predecessors-in-interest, which declared Julian Sta. Ana and Mercedes Sta. Ana the absolute owners of the lot and ordered its registration. This 1967 decision was affirmed by the Court of Appeals, and an entry of judgment was issued in 1992. In 1999, respondents filed an Urgent Ex Parte Motion for Issuance of a Decree, which the trial court granted, directing the Land Registration Authority (LRA) to issue the decree.
The LRA, through a Supplementary Report, informed the trial court that a portion of Lot 459 appeared to be already covered by a prior registration proceeding in Cadastral Case No. 10, Cadastral Record No. 984, and that issuing a new decree would result in double registration. The LRA reported that it had no copy of the cadastral decision and that efforts to obtain details from other government agencies were inconclusive. The trial court then ordered respondents to submit an amended plan segregating the allegedly titled portion. Respondents filed a Manifestation stating they could not comply because no copy of the cadastral decision existed, no record of any patent or title for the lot could be found in relevant agencies, and the only reference was a notation in the LRA’s Record Book.
The trial court, convinced by respondents’ efforts and the lack of evidence of an existing title, granted their motion for reconsideration and ordered the LRA to issue a title in the name of the respondents’ predecessors, pursuant to the 1967 decision. The Republic’s motion for reconsideration was denied. The Republic filed a petition for certiorari with the Court of Appeals, which dismissed the petition, affirming the trial court’s order. The Court of Appeals found that since no existing title from Cadastral Case No. 10 could be found in the records, there was no risk of double titling.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s order directing the LRA to issue a title to respondents, despite the LRA’s report indicating a potential prior registration of a portion of the lot.

RULING

The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals. The ruling upheld the trial court’s directive for the LRA to issue the title based on the final and executory 1967 decision. The Court found that the LRA’s report, while noting a notation of a prior cadastral decision, ultimately revealed that no copy of that decision existed in the LRA’s available records and that subsequent inquiries with other government agencies yielded no record of any patent, title, or subdivision for the subject lot. The respondents had exhausted all means to comply with the segregation order but were unable to do so due to the absence of any verifiable record of the alleged prior title. Consequently, the Supreme Court agreed with the lower courts that issuing the decree pursuant to the 1967 decision would not result in a duplication of titles, as there was no evidence of an actually existing prior certificate of title over the land.