G.R. No. L-54094. August 30, 1982.
ALABANG DEVELOPMENT CORPORATION and RAMON D. BAGATSING, petitioners, vs. HON. MANUEL E. VALENZUELA, (Presiding Judge, CFI, Rizal, Pasay City, Branch XXIX) and NICOLAS A. PASCUAL, et al., and the REGISTER OF DEEDS OF RIZAL, respondents.

FACTS

Petitioners Alabang Development Corporation and Ramon D. Bagatsing are registered owners of parcels of land in Barrio Cupang, Muntinlupa, evidenced by Transfer Certificates of Title. These lands, part of the Alabang Hills Village Subdivision, have been sold to innocent purchasers who have been in open and continuous possession since 1969. In 1977, respondents (the Pascual family) filed a petition for reconstitution of a lost certificate of title allegedly issued in 1914 in the name of Manuela Aquial, covering Lots 2 and 4 of Plan II-4374. Petitioners alleged that the technical descriptions of the title sought to be reconstituted overlap their registered properties.
Petitioners asserted they were not served with notice of the hearing for the reconstitution petition, despite being actual possessors and registered owners of the affected lands. The Court of First Instance of Pasay City granted the reconstitution. Petitioners then filed the instant petition for certiorari and prohibition, arguing the lower court acted without jurisdiction due to lack of mandatory notice and fatal defects in the petition for reconstitution.

ISSUE

Whether the Court of First Instance acted without jurisdiction in granting the reconstitution of title.

RULING

Yes, the decision granting reconstitution is null and void for lack of jurisdiction. The Supreme Court, citing its controlling pronouncements in the related case of Director of Lands vs. Court of Appeals, ruled that the petition for reconstitution suffered from jurisdictional infirmities. First, the petition and the published notice lacked essential data mandatorily required by Republic Act No. 26, the law governing reconstitution of lost titles. Second, and just as critically, the lower court invalidly issued the decision without actual and personal notice having been served upon the indispensable parties in interest—the possessors, actual occupants, and adjoining owners of the property involved.
The Court emphasized that petitioners, as registered owners and actual possessors of the overlapping lands, were indispensable parties. The failure to serve them with notice was a fatal defect that deprived the court of jurisdiction to render a valid judgment. The purpose of the mandatory notice requirement is to afford all interested parties, especially those in possession, the opportunity to be heard and contest the reconstitution, thereby preventing fraudulent claims and ensuring the stability of registered titles. Consequently, the reconstituted title was declared void. The Court made permanent the temporary restraining order it had issued and directed an investigation into the possible fabrication of the decree used in the reconstitution.