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REPUBLIC v. PILAR ESTIPULAR

FACTS:

The case involves a Petition for Reconstitution of Title filed by Pilar Estipular before the Regional Trial Court of La Union. Pilar claimed to be the only surviving legal heir of Fermin Estipular, who held Certificate of Title No. 154 for a parcel of land in Barrio Liquicia, Caba, La Union. Fermin's certificate was either lost or destroyed during the last World War. Pilar requested the reconstitution of the title and complied with the publication and posting requirements under Republic Act No. 26. The Notice of Hearing was published in the Official Gazette and posted at the main entrance of the Municipal Building of Caba, but it was not posted at the main entrance of the provincial capitol building. The trial court granted the petition, and this decision was affirmed by the Court of Appeals. The Republic of the Philippines filed a Petition for Review, arguing that there was no jurisdiction due to the failure to post the Notice of Hearing at the provincial capitol building.

ISSUES:

  1. Whether or not supposed substantial compliance with the requirements of Republic Act No. 26 is sufficient to confer jurisdiction on the trial court over the case.

RULING:

  1. The Court ruled that substantial compliance with the requirements of Republic Act No. 26 is not sufficient to confer jurisdiction on the trial court over the case. The requirements under RA No. 26 are mandatory and jurisdictional, and strict compliance with them is necessary for the trial court to acquire jurisdiction.

PRINCIPLES:

  1. Jurisdiction over Subject Matter: Jurisdiction over the subject matter or nature of the action is conferred only by the Constitution or by law and cannot be granted by the agreement of the parties, acquired, waived, enlarged, or diminished by any act or omission of the parties, or conferred by the acquiescence of the courts.

  2. Mandatory and Jurisdictional Requirements: The requirements for reconstitution of title under Republic Act No. 26 are mandatory and jurisdictional. Compliance with these requirements is imperative for the court to acquire jurisdiction.

  3. Strict Compliance: Strict compliance with the requirements of the law is necessary for the trial court's acquisition of jurisdiction, and substantial compliance is not sufficient.

  4. Notice Requirements: The notice of hearing must be published, posted, and mailed as directed by the court. All three methods—publication in the Official Gazette, posting at the main entrances of municipal and provincial buildings, and mailing to known interested parties—must be fulfilled.

  5. Principle of Substantial Compliance: The principle of substantial compliance cannot be applied to jurisdictional requirements, particularly in the context of reconstitution of title where strict adherence to statutory procedures is required.