GR L 66344; (July, 1990) (Digest)
G.R. No. L-66344. July 2, 1990.
MIGUEL LANZONA (DECEASED) and ILUMINADA E. LANZONA, petitioners, vs. HON. INTERMEDIATE APPELLATE COURT and EMILIO ALVAREZ, respondents.
FACTS
The case involves a dispute over Lot No. 384 in Davao. On October 1, 1940, the Court of First Instance of Davao, through Judge Enrique Fernandez, rendered a decision adjudicating the lot to Constancio Guzman, the predecessor-in-interest of respondent Emilio Alvarez. This decision referenced a prior Supreme Court ruling. Constancio Bolcan, a claimant to improvements on the lot, appealed this decision, but all records were destroyed during World War II and never reconstituted. Despite the missing records, a decree of registration and Original Certificate of Title (OCT) No. Q-217 were issued in favor of Guzman in 1967. Petitioners Miguel and Iluminada Lanzona, claiming to have acquired Bolcan’s rights since 1942 and possessing the land for over 25 years, filed a petition to review the decree, alleging fraud in its issuance. The trial court granted their petition, annulled Guzman’s title, and ordered a new title issued to the Lanzonas.
ISSUE
Whether the Court of Appeals erred in reversing the trial court and in upholding the validity of the decree of registration and title issued to Guzman, thereby dismissing the Lanzonas’ petition for review.
RULING
The Supreme Court denied the petition and affirmed the Appellate Court’s decision. The legal logic is anchored on the finality of judgments and the limited scope of review. First, the Court upheld the finding that no extrinsic fraud, as required under the Land Registration Act to reopen a decree, was present. The alleged errorโJudge Fernandez’s reliance on an uncertified copy of a Supreme Court decisionโconstituted at most an error of judgment or in the appreciation of evidence, not the deliberate fraud necessary for a review. Second, the Court affirmed that the 1940 decision had become final and executory. The purported appeal by Bolcan was not substantiated, and the duty to reconstitute the lost records fell upon the appealing party. Failure to initiate reconstitution was deemed an abandonment of the appeal, rendering the decision final. A reconstituted copy of the decision was sufficient, and the trial court erred in declaring it ineffective. Third, the petitioners’ alternative claim of ownership by acquisitive prescription involved factual determinations. The Appellate Court’s finding that the Lanzonas failed to prove their possessed land was identical to Lot 384 is binding on the Supreme Court, which does not re-evaluate evidence under a petition for review limited to questions of law. Thus, no reversible error was committed.
