G.R. No. 241890 , May 03, 2021
Republic of the Philippines, Petitioner, vs. Avelino Manansala, Heir of the Late Fel M. Manansala, Represented by Esmeraldo M. Manansala, Respondent.

FACTS

Respondent Avelino Manansala, sole heir of Fel Manansala, filed a petition for judicial reconstitution of the original copies of Transfer Certificates of Title (TCT) Nos. T-4773 and T-2822, registered in Fel’s name, which were allegedly among those burned in a 1959 fire at the Cavite Registry of Deeds (RD). The petition was based on the owner’s duplicate copies in his possession. The Land Registration Authority (LRA) issued an initial Report (First Report) dated May 26, 2014, stating that the information on the submitted TCT copies did not match LRA records and that the titles “did not exist” in the Cavite RD. Respondent submitted counter-evidence, including a DENR certification, and requested a re-evaluation. The LRA then issued a subsequent Report (Second Report) dated February 6, 2015, which reversed the First Report, finding the technical descriptions on the TCT copies correct and that the plotted lots did not overlap with other properties. The RTC granted the petition for reconstitution. The CA affirmed the RTC Decision. The Republic, through the OSG, appealed, arguing the CA erred in affirming the RTC Decision based on the conflicting LRA Reports.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court Decision, which granted the petition for reconstitution of the alleged lost TCTs based on the conflicting First and Second Reports issued by the LRA.

RULING

The Petition is granted. The Supreme Court reversed the CA Decision. The required quantum of evidence in reconstitution proceedings is not mere preponderance of evidence but clear and convincing evidence. The conflicting LRA Reports created serious doubt regarding the existence and authenticity of the titles sought to be reconstituted. The First Report categorically stated the titles did not exist per LRA records, while the Second Report, issued by the same LRA official without explanation for the reversal, merely found the technical descriptions correct upon replotting. This discrepancy, coupled with the lack of testimony from the LRA official to explain the conflict and the failure to establish that the original titles were validly issued and existing at the time of their alleged loss, means the respondent failed to present the clear and convincing evidence required by law. The RTC thus erred in granting the petition, and the CA erred in affirming it.