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FIDELA R. ANGELES v. SECRETARY OF JUSTICE

FACTS:

The case involves a dispute over the validity of Original Certificate of Title (OCT) No. 994 and the issuance of transfer certificates of title (TCT) based on it. On May 3, 1965, the petitioner and other alleged heirs of Maria de la Concepcion Vidal filed a special civil action for partition and accounting of the Maysilo Estate covered by OCT No. 994. They claimed to be entitled to inherit Vidal's share in the property. Some of the alleged heirs were able to procure TCTs over portions of the estate. In a previous case, the Court held that OCT No. 994 dated April 19, 1917, was the valid title by virtue of the prior registration rule. The RTC granted the partition and accounting prayed for by the plaintiffs and ordered the issuance of TCTs in the names of all the co-owners. However, the respective Registers of Deeds refused to comply with the RTC Order, awaiting word from the LRA Administrator.

The LRA Administrator, Mr. Alfredo R. Enriquez, informed the petitioner's counsel that their request cannot be granted based on the directive of the DOJ, which found that there is only one OCT No. 994 issued on May 3, 1917. This directive was issued based on the findings of the Composite Fact-Finding Committee and was also supported by the Senate Committee on Justice and Human Rights and Urban Planning. The LRA Administrator stated that the surviving heirs claiming rights to the property were found to be not the true and legal heirs of Vidal. The former Deputy Registrar of Deeds of Caloocan City was found to have acted maliciously, fraudulently, and in bad faith. The Registrar of Deeds of Caloocan City was also found to have acted maliciously, fraudulently, and in bad faith. The LRA Administrator further stated that OCT No. 994 was intact and being kept in the LRA to prevent alteration and tampering. Compliance with the order directing the issuance of TCTs based on OCT No. 994 was questioned on the grounds that OCT No. 994 had been cancelled and that the plan and descriptions of the lands were not based on an approved subdivision plan. The petitioner argues that the respondent, Guingona, issued an indorsement that modified a previous ruling of the Supreme Court and usurped judicial functions. The petitioner also claims that Guingona was responsible for the issuance of a circular without hearing or notice to the parties-in-interest. The petitioner seeks relief from the court, claiming that there is no other adequate remedy available.

The petitioner filed a petition for mandamus to compel the respondent, Teofisto Guingona Jr., to revoke and withdraw a 1st Indorsement issued by the DOJ which directed the LRA to suspend all proceedings on the application for the registration of certain parcels of land known as the Maysilo Estate. Guingona raised several grounds for the denial of the petition, including that he was no longer the Secretary of Justice and therefore not a real party-in-interest; the 1st Indorsement was an administrative issuance and did not alter any judgment of the Court; and that mandamus was not the appropriate remedy to enforce claims for damages. Guingona contended that the committee created by the DOJ was tasked with conducting a fact-finding inquiry and formulating policies, procedures, and courses of action to address the issue of fake land titles, including those relating to the Maysilo Estate. Based on the committee's report, Guingona issued the 1st Indorsement as an administrative issuance of the DOJ.

ISSUES:

  1. Whether the fact-finding investigation conducted by the committee created by the Department of Justice (DOJ) was merely administrative in nature or had the power to alter or supplant a judgment of the Supreme Court.

  2. Whether the petitioner was denied due process based on the issuance of the 1st Indorsement by the Committee and the opportunity given to present her case to the LRA legal staff.

  3. Whether the claim for damages should be dismissed for failure to specify the amount and pay the required docket fees.

  4. Whether public respondents unlawfully neglected to perform their duties by refusing to issue the questioned transfer certificates of title to the petitioner and her co-plaintiffs.

  5. Whether public respondents unlawfully excluded the petitioner from the use and enjoyment of the claimed right, warranting the issuance of a writ of mandamus against them.

  6. Whether the Register of Deeds can be compelled by mandamus to comply with the RTC Order for the issuance of transfer certificates of title.

  7. Whether the LRA Administrator can be mandated by the Court to require the Register of Deeds to comply with said Order.

  8. Whether the findings of the Department of Justice (DOJ) and the Senate regarding OCT No. 994 are binding in this case.

  9. Whether the Special Division of the Court of Appeals properly evaluated the evidence and made accurate conclusions with regard to the status of the original title and its subsequent conveyances.

  10. Whether the partition and accounting prayed for by the petitioner and co-plaintiffs can still prosper given the conclusive findings on the non-existence of a second OCT No. 994.

  11. Whether the requirements for the issuance of a writ of mandamus have been proven by the petitioner.

RULING:

  1. The fact-finding investigation conducted by the committee was purely administrative and did not have the power to alter or supplant a judgment of the Supreme Court.

  2. The petitioner was not denied due process since the 1st Indorsement was issued prior to the order that gave rise to her alleged rights and interests. The opportunity given to present her case to the LRA legal staff satisfies the requirements of due process.

  3. Dismissal of the claim for damages is appropriate since the petitioner failed to specify the amount and pay the required docket fees.

  4. It was not unlawful for public respondents to refuse compliance with the RTC Order, and the act being requested of them is not their ministerial duty; hence, mandamus does not lie and the petition must be dismissed.

  5. The Register of Deeds cannot be compelled by mandamus to comply with the RTC Order since there were existing transfer certificates of title covering the subject parcels of land and there was reason to question the rights of those requesting for the issuance of the TCTs.

  6. The LRA Administrator cannot be mandated by the Court to require the Register of Deeds to comply with said Order, as there was sufficient basis for public respondents to refuse to comply with the RTC Order, given the finding that the OCT No. 994 dated April 19, 1917, on which the petitioner and her co-plaintiffs anchored their rights, did not exist.

  7. The Supreme Court dismissed the petition for lack of merit. The Court held that the findings of the DOJ and the Senate regarding OCT No. 994 are not binding and cannot overturn judicial decisions. The Court emphasized that the reports can only be taken into account as evidence on the same level as other pieces of evidence submitted by the parties. The Court also recognized the authority and discretion of the Special Division of the Court of Appeals in evaluating the evidence and making conclusions on the status of the original title and its subsequent conveyances. The Court affirmed the Special Division's finding that there is only one OCT No. 994 with a registration date of 3 May 1917, and declared that the OCT No. 994 with a registration date of 19 April 1917 is null and void. Considering these findings, the Court concluded that the partition and accounting prayed for by the petitioner and co-plaintiffs can no longer prosper. Lastly, the Court ruled that the petitioner failed to prove the requirements for the issuance of a writ of mandamus.

PRINCIPLES:

  • Administrative investigations are purely administrative in nature and do not have the power to alter or supplant a judgment of the Supreme Court.

  • Due process requires an opportunity to be heard, which may be satisfied by the opportunity to present one's case to the proper administrative body.

  • Claims for damages should be properly specified and the required docket fees must be paid for such claims to be considered by the courts.

  • Mandamus is employed to compel the performance of a ministerial duty, but not to compel the performance of a discretionary duty. Mandamus will not issue to enforce a right that is in substantial dispute or to which a substantial doubt exists.

  • Mandamus is also available to compel action when refused in matters involving judgment and discretion, but not to direct the exercise of judgment or discretion in a particular way.

  • The issuance of a decree of registration by LRA officials is not a purely ministerial duty in cases where it would result in the double titling of the same parcel of land.

  • Mandamus can only be awarded when the petitioner's legal right to the performance of the specific act being compelled is clear and complete.

  • A clear legal right is one that is indubitably granted by law or inferable as a matter of law.

  • Mandamus cannot be granted when the right sought to be enforced is in substantial doubt or dispute.

  • The existence of OCT No. 994 dated April 19, 1917, where the petitioner derived her rights, has been declared inexistent and void.

  • Judicial decisions cannot be overturned by non-judicial reports, such as those by the DOJ and the Senate.

  • Reports by the DOJ and the Senate may be taken into account as evidence, but they must still undergo judicial scrutiny and analysis.

  • The Special Division of the Court of Appeals has the authority and discretion to evaluate evidence and make conclusions on the status of title and its subsequent conveyances.

  • Only one OCT No. 994 exists with a registration date of 3 May 1917, and any OCT No. 994 with a registration date of 19 April 1917 is null and void.

  • The requirements for the issuance of a writ of mandamus must be proven for the writ to be granted.