G.R. No. L-46500 & L-48114 December 29, 1962
Testate Estate of the Deceased Maria Jacoba Cruz. Lutgarda Yatco, et al., movants-appellees, vs. Daniel F. Cruz, et al., oppositor-appellants.

FACTS

This is a petition for the reconstitution of Supreme Court decisions in two consolidated testate estate proceedings involving the deceased Maria Jacoba Cruz. The original records were destroyed during the Pacific War. For G.R. No. 46500 , petitioners submitted the original record on appeal from the Court of First Instance and a published copy of the Supreme Court’s October 25, 1949 decision penned by Chief Justice Moran, which legalized certain wills. For G.R. No. 48114, a subsequent appeal, petitioners submitted a typewritten copy of the alleged October 5, 1942 decision penned by Justice Paras. This copy was certified as true and correct by Justice Paras himself in 1961. Corroborative evidence, including a notice from the lower court, was also presented.
Various oppositors objected to the reconstitution. Their primary argument was that the petition, filed in 1960, was filed beyond the period allowed under Republic Act No. 441 , which governs the reconstitution of records of pending cases destroyed by the war. They also questioned the authenticity of the typewritten copy of the Paras decision and argued that reconstitution was futile since more than ten years had passed, potentially barring enforcement of the judgments.

ISSUE

The principal issue is whether the Supreme Court can grant the petition for the reconstitution of its final and executory decisions and related records, notwithstanding the oppositions based on statutory time limits and authenticity concerns.

RULING

The Supreme Court granted the petition and ordered full reconstitution. The legal logic proceeds as follows: First, the applicable statutes cited by oppositors, Republic Act No. 441 and Act No. 3110 , are inapplicable. By their explicit titles and terms, these laws govern the reconstitution of records for pending judicial proceedings. The cases subject of the petition, G.R. No. 46500 and G.R. No. 48114, were already finally decided by the Supreme Court; they are not pending. Therefore, the statutory time limits under those laws do not bar the present petition.
Second, the Court possesses the inherent power to reconstitute the records of its finished cases. This authority is derived from its constitutional role and is recognized under Rule 124, Section 5(h) of the Rules of Court. The Court cited its own precedent in Allingag vs. Del Valle-Cruz, where it resolved that courts have inherent power to reconstitute records of finished cases at any time, making statutory limitations for pending cases irrelevant.
Third, the evidence submitted is sufficient to establish the decisions’ contents. For the Moran decision, the published copy in the Lawyers’ Journal is reliable. For the Paras decision, the typewritten copy certified as true by the ponente himself, Justice Paras, carries great weight. The Court found this certification, coupled with the corroborative notice from the lower court and the logical coherence of the decision with the known pleadings and issues of the case, to be satisfactory proof of authenticity. The Court deferred ruling on the oppositors’ claim that the judgments may no longer be enforceable due to the passage of time, holding that such a question is premature and should be addressed only after reconstitution if and when enforcement is sought.