G.R. No. 94033 May 29, 1995
FELICIANO RAMOS, Substituted by his heirs through VALERIANA VDA. DE RAMOS, petitioners, vs. HONORABLE FRANCISCO C. RODRIGUEZ, Presiding Judge, RTC, Branch 77, San Mateo, Rizal and LAND REGISTRATION AUTHORITY, respondents.

FACTS

Petitioner Feliciano Ramos applied for the registration of a parcel of land in Rodriguez, Rizal. Upon his death, his heirs were substituted. The trial court issued an order of general default and subsequently rendered a decision on July 28, 1988, adjudicating the land to the petitioners. On September 12, 1988, the court issued an Order for Issuance of Decree, directing the Land Registration Authority (LRA) to prepare the decree and certificate of title.
Instead of complying, the LRA Administrator submitted a report dated September 26, 1988, recommending that the decision be set aside. The report revealed that the subject lot was part of a property already covered by Transfer Certificate of Title (TCT) No. 8816 issued in 1924 in the name of Payatas Estate Improvement Company. Petitioners later claimed this title was fraudulent but presented no evidence. The trial court initially noted the report but opined it could not set aside its final decision, suggesting the proper remedy was an action for annulment.

ISSUE

Whether the trial court committed grave abuse of discretion in granting the LRA’s motion for reconsideration, setting aside its final decision and order for issuance of a decree, upon finding the land was already covered by an existing Torrens title.

RULING

The Supreme Court denied the petition and affirmed the trial court’s order. The legal logic is anchored on the unique nature of land registration proceedings. The Court reiterated the doctrine from Gomez v. Court of Appeals that a decision in a land registration case does not become incontrovertible until after the expiration of one year from the entry of the final decree of registration by the LRA. Since no final decree had been issued here, the decision remained under the control and discretion of the court.
Contrary to petitioners’ claim, the duty of the LRA to issue a decree is not purely ministerial when it discovers a legal impediment, such as an existing certificate of title. In such a case, the LRA, acting as an officer of the court, has a duty to refer the matter to the court. The trial court, therefore, correctly acted on the LRA’s report and motion. While petitioners raised a procedural issue regarding representation by the Solicitor General, the Court emphasized that procedural lapses may be overlooked in the interest of substantive justice. A strict adherence to rules would compel the LRA to issue a decree for land already titled under the Torrens system to another, which is precisely what the system seeks to prevent. TCT No. 8816 enjoys a conclusive presumption of validity, and petitioners’ application constituted an impermissible collateral attack on that title.