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SPS. ANDRES SUOBIRON v. CA

FACTS:

Petitioner-spouses Andres Suobiron and Socorro Suobiron, Jose Sullano Jr. and Ireneo Ferraris filed a case to annul the orders and decrees issued by the Court of First Instance of Iloilo in LRC Case No. 673, as well as the corresponding certificates of title, claiming that the court did not have jurisdiction and the requirements for reconstitution of court records were not complied with. Private respondents countered these allegations and also claimed for the delivery of the property in litigation and payment of produce.

The trial court ruled that the two parcels of land were subject to LRC Case No. 673, with parties including the Director of Lands and the Lorezo family as oppositors. A judgment was previously rendered in favor of spouses Luis Adelantar and Fortunata Ponce, but the appeal filed by the oppositors was dismissed. Following the reorganization of the court in 1945, the reconstitution of the records in LRC Case No. 673 was ordered, and a motion for reconstitution filed by Luis Adelantar was granted. As a result, decrees and certificates of title were issued in their favor.

However, Quintin and Bernabe Lorezo entered the litigated property and took possession of the produce to the detriment of the registered owners. The Adelantars filed an action for recovery of possession against the Lorezos and obtained judgment in their favor. Despite this, the Lorezos and other individuals re-entered the premises after it was delivered by the Provincial Sheriff to the Adelantars. The property then became the subject of a cadastral survey, with Fortunata Ponce and other heirs of Luis Adelantar asserting ownership. Their complaint for quieting of title and recovery of possession was dismissed without prejudice.

Subsequently, the petitioners sought the annulment of the certificates of title of the Adelantars, but their action was dismissed. They then filed a complaint claiming co-ownership of the property. However, the trial court dismissed their complaint, ordered them to vacate the property, and pay damages to the private respondents. The Court of Appeals affirmed the trial court's decision, with the exception of attorney's fees, which were deleted. The petitioners now raise issues concerning the compliance with Act 3110, the conclusiveness of the decision in Civil Case No. 938, and their liability for damages.

ISSUES:

  1. Whether the requirements for the reconstitution of a court record were complied with in this case.

  2. Whether the decision in Civil Case No. 938 is conclusive upon the parties.

  3. Whether the failure to serve notice on the petitioner is relevant to the reconstitution proceedings.

  4. Whether the presentation of the order instead of the resolution in the reconstitution proceedings constitutes substantial compliance with the law.

  5. Whether the decision in Civil Case No. 938 is conclusive upon the parties and their successors-in-interest.

  6. Whether the possession of the petitioner in good faith was legally interrupted when they were served summons.

  7. Whether the possession of the petitioner in good faith ceased and they lost the right to the fruits when they were served summons.

RULING:

  1. Yes, the requirements for the reconstitution of a court record were fulfilled in this case. The clerk of court sent a notice to the presiding judge informing him of the destruction of all court records in the province. The judge then immediately issued an order for their reconstitution, which was published in newspapers of general circulation in the province. The movant also served copies of the motion for reconstitution on the oppositors through their respective counsel.

  2. The decision in Civil Case No. 938 is conclusive upon the parties. The issue of the legality of the reconstitution of LRC Case No. 673 was involved in that case, and damages were properly awarded against the parties who claimed lawful possession of the parcels of land.

  3. The failure to serve notice on the petitioner is no longer relevant to the reconstitution proceedings.

  4. The presentation of the order instead of the resolution in the reconstitution proceedings constitutes substantial compliance with the law.

  5. The decision in Civil Case No. 938 is conclusive upon the parties and their successors-in-interest.

  6. The possession of the petitioner in good faith was legally interrupted when they were served summons.

  7. The possession of the petitioner in good faith ceased and they lost the right to the fruits when they were served summons.

PRINCIPLES:

  • Section 1, 2, and 3 of Act 3110 prescribe the procedure for the reconstitution of a court record in case of loss or destruction.

  • Substantial compliance with the law is sufficient, and it is not necessary for notice of the destruction to be served on all lawyers or parties interested in the cases affected.

  • Notice of the destruction, order for reconstitution, and publication in newspapers of general circulation are among the requirements for the reconstitution of a court record.

  • Substantial compliance with the law is sufficient.

  • The decision in one case can be conclusive upon the parties and their successors-in-interest.

  • Possession in good faith may lose its character when the possessor is made aware that the possession is improper or wrongful.

  • Possession in good faith ceases and the right to the fruits is lost when the possessor is served summons in connection with a complaint.