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REPUBLIC v. CONCEPCION LORENZO

FACTS:

The case involves a petition for the reconstitution of Original Certificate of Title (OCT) No. 3980. The petitioners, who are the heirs of Pedro Fontanilla and Concepcion Lorenzo, filed the petition due to the loss or destruction of the owner's duplicate copy of the title. They claimed that the original and office file copy of the OCT were also lost and burned in a fire in 1976.

The trial court granted the petition and directed the Register of Deeds to reconstitute OCT No. 3980. The Republic of the Philippines, represented by the Office of the Solicitor General, appealed the ruling to the Court of Appeals. They argued that there was insufficient evidence to support the reconstitution and that the petitioners failed to present a valid basis or source for reconstitution.

The Court of Appeals dismissed the appeal, affirming the trial court's decision. Dissatisfied, the Republic filed a petition for review before the Supreme Court. The main issue at hand is whether the reconstitution of OCT No. 3980 was done in accordance with the applicable law and jurisprudence.

ISSUES:

  1. Whether the respondents have proven the loss or destruction of the owner's duplicate copy of OCT No. 3980.

  2. Whether the respondents have shown adequate proof that a Torrens certificate of title was issued covering the subject parcel of land or that the same piece of land is what is covered by the allegedly lost or destroyed OCT No. 3980.

  3. Whether the documents submitted by the respondents, such as the Certification from the Register of Deeds and the Certification from the Land Registration Authority, support their assertion that OCT No. 3980 did exist prior to its loss or destruction.

  4. Whether the deed of sale and the index of decree presented by the respondents can be relied upon as bases for the reconstitution of the Torrens certificate of title.

RULING:

  1. The petition is granted. The Court reversed and set aside the Decision of the Court of Appeals and the Regional Trial Court. The petition for reconstitution is denied.

PRINCIPLES:

  • In order to reconstitute a lost or destroyed certificate of title, the petitioner must prove the loss or destruction of the certificate by satisfactory evidence. (Section 109, Presidential Decree No. 1529)

  • The absence of any document mentioning the number of the certificate of title and the date when it was issued does not warrant the granting of a petition for reconstitution. (Republic v. El Gobierno de las Islas Filipinas; Tahanan Development Corp. v. Court of Appeals)

  • The State cannot be estopped by the omission, mistake, or error of its officials or agents. The absence of opposition from government agencies does not bar the Republic from assailing the decision granting a petition for reconstitution if there is no merit to the petition.