G.R. No. L-39248. May 07, 1976

Background

The case revolves around an increase in the area of land originally registered under the Original Certificate of Title No. 5609 and later under various Transfer Certificates of Title in the names of the heirs of Luisa Villa Abrille. The increase, totaling 82,127 square meters, was adjacent to the Davao River and allegedly took place a long time ago. The Republic of the Philippines, represented by the Director of Lands, filed a civil action for annulment of the certificate of title against the Estate of Luisa Abrille and others.

Parties involved

• Plaintiff: Republic of the Philippines (represented by the Director of Lands)

• Defendants: Estate of Luisa Abrille, Huang Siu Sin (Administrator), Land Registration Commissioner, and the Register of Deeds of Davao City, along with heirs Huang Siu Sin, Milagros Huang, Miguel Huang, Josefino Huang, and Iap Tong Ha

Contentions of proceedings

• The defendants sought to include the increase in the area through a petition for approval of Subdivision Plan (LRC) Psd-79322, recommended by the Commissioner of Land Registration.

• The trial court noted the lack of notice to interested persons and the incorrect procedure followed in including the increase in the titled land through subdivision planning, instead of initial registration proceedings.

• The court rendered a judgment canceling Transfer Certificates of Title Nos. T-20725, T-20701, T-20713, and T-20690 and ordering new certificates after segregating the increased area.

• The heirs of Luisa Villa Abrille appealed, arguing the lower court erred in its decision, and that they believed they acted within the law. They also contended that since the government was aware of the increase in area, they should not suffer due to the wrong procedure.

• The Court of Appeals certified the case to the Supreme Court.

Supreme court decision

• The Supreme Court held that the lower court acted correctly, affirming the judgment.

• The Court found that the petitioning of the court for approval of the Subdivision Plan was unwarranted and irregular, and the increase in the area should have been dealt with through land registration proceedings under Act 496.

• The Court emphasized that the specific requirements for original registration of land under Act 496 had not been satisfied, including proper surveying, notice, publication, hearing, and issuance of a decree by a competent jurisdiction.

• The judgment of the lower court was affirmed in toto, with no special pronouncement as to costs.

In conclusion, the case underscores the importance of adhering to legal procedures in land registration, and the improper inclusion of an increased area via a subdivision plan was found to be invalid. The Supreme Court's ruling upheld the cancellation of the transfer certificates of title covering the increased area, requiring proper registration proceedings to be followed.

Important dates

• Original Certificate of Title No. 5609 Issuance [Date not mentioned in the text]: Registered in the name of Francisco Villa Abrille Lim Juna, covering the original area.

• Transfer to Luisa Villa Abrille, TCT No. T-1439 [Date not mentioned in the text]: Land was subsequently registered in the name of Luisa Villa Abrille.

• Subdivision Plan (LRC) Psd-71236, Derivative Titles Issued [Date not mentioned in the text]: Four Transfer Certificates of Title were issued: T-20725 to Milagros Huang; T-20701 to Josefino Huang; T-20713 to Miguel Huang; T-20690 to Huang Siu Sin. The area increased to 607,779 square meters.

• Filing of Civil Action [Date not mentioned in the text]: Republic of the Philippines files a civil action for annulment of certificate of title against the Estate of Luisa Abrille and others.

• Petition for Approval of Subdivision Plan (LRC) Psd-79322 [Date not mentioned in the text]: Filed with the court, seeking to include the increased area in the title.

• Trial Court Judgment [January 27, 1970]: Judgment rendered cancelling TCT Nos. T-20725, T-20701, T-20713, and T-20690, and ordering new certificates of title after segregating the increased area.

• Filing of Appeal to the Court of Appeals [Date not mentioned in the text]: Defendant Heirs of Luisa Villa Abrille appealed the trial court's judgment.

• Court of Appeals Resolution [July 22, 1974]: The Court of Appeals certified the case to the Supreme Court for consideration and final disposition.

• Supreme Court Decision [Date not mentioned in the text]: Supreme Court affirmed the judgment of the lower court in toto, ordering the cancellation of the aforementioned TCTs.

Titles and derivatives

• Original Certificate of Title (OCT) No. 5609:

  • Registered in the name of Francisco Villa Abrille Lim Juna.

• Transfer Certificate of Title (TCT) No. T-1439:

  • Registered in the name of Luisa Villa Abrille.

• Subdivision Plan (LRC) Psd-71236, Derivative Titles:

  • TCT No. T-20725 in the name of Milagros Huang.

  • TCT No. T-20701 in the name of Josefino Huang.

  • TCT No. T-20713 in the name of Miguel Huang.

  • TCT No. T-20690 in the name of Huang Siu Sin.

Reference

Supreme Court of the Philippines. (1976). Villa Abrille, et al. v. Court of Appeals, et al., G.R. No. L-39248. Retrieved from https://lawphil.net/judjuris/juri1976/may1976/gr_39248_1976.html