DMCI Project Developers, Inc. vs. Bernadas

A final Labor Arbiter order nullifying redemption and quitclaim documents may be declared registrable through LRA consulta without a prior writ of execution, registrability being distinct from actual registration, especially where the Rule 43 appeal from the consulta was filed out of time and the labor judgment had become final and immutable.

Bernadas et al. were complainants in an NLRC labor case against Liberty Transport Corp. and/or Mr. and Mrs. Honorato Lacsina, while DMCI Project Developers, Inc. later asserted ownership over the levied Taguig lot through Taguig Land Development Corporation by merger. The governing frameworks were the NLRC Manual on Execution of Judgment for enforcement of labor awards and Presidential Decree No. 1529 for registration of instruments, ministerial duties of Registers of Deeds, and consulta to the Land Registration Authority on doubtful registration questions.

The subject lot comprised 16,461 square meters in Taguig City covered by TCT No. 25491 issued to Honorato Lacsina married to Milagros Lacsina, Reynaldo Bonifacio Lacsina married to Evelyn Lacsina, and Renato G. Dionisio married to Corazon Platon Dionisio. Bernadas et al. instituted NLRC NCR Case No. 00-08-04508-96 against Liberty Transport Corp. and/or Mr. and Mrs. Honorato Lacsina, obtained a favorable award, and caused annotation of a Notice of Levy as Entry No. 5371/25491 on March 15, 2006 against the registered owners' title, rights, interests, shares and participations. At the April 3, 2009 auction sale, Bernadas et al. emerged as winning bidder, and the Register of Deeds annotated Entry No. 3252 Certificate of Sale on June 3, 2009 in their favor for P1,915,800.00, with the redemption period to expire under pertinent legal guarantees.

On June 29, 2009, Bernadas et al. executed a Deed of Sale and/or Certificate of Redemption of Real Property ceding ownership to DMCI for P1,915,800.00 representing the total monetary award, and on the same date executed a Release and Quitclaim discharging Honorato and Milagros Lacsina and DMCI from liabilities in the labor case. Both DMCI and Bernadas et al. then petitioned the Register of Deeds of Taguig City to cancel the Notice of Levy and Certificate of Sale. Thereafter Taguig Land Development Corporation acquired the lot and secured TCT No. 12619, then transferred it to DMCI by merger.

Contrary to those conveyances, Bernadas et al., through attorney-in-fact Evelyn Insilay-Rebueno, moved before the NLRC to nullify the Deed of Sale and/or Certificate of Redemption and Release and Quitclaim as spurious and falsified. According to Bernadas et al., signatory Lidfiel Marikit had died on January 15, 1997, signatory Jerson Talam was no longer part of the judgment and could not be found, they had not received the P1,915,800.00 monetary claims but only P100,000.00 from a surety company, and their signatures were stealthily obtained on paper represented as a receipt for P100,000.00. A Sheriff's Final Deed of Sale had already been issued by NLRC Sheriff Ramon Nonato P. Dayao to consolidate ownership in their favor. DMCI opposed, arguing Evelyn's agency was extinguished under Article 1919 of the New Civil Code upon collection and that the judgment had been fully paid and satisfied.

The Labor Arbiter found DMCI was not a redemptioner under Section 11, Rule VII of the NLRC Manual, neither a losing party or successor-in-interest nor a lien creditor, noted DMCI's earlier third-party claim had been dismissed for lack of evidence and failure to annotate for 11 years and rejected by the Court of Appeals in a July 31, 2009 Decision that became final and executory, and viewed quitclaims with disfavor as contrary to public policy. The NLRC affirmed, finding DMCI had implicitly admitted Evelyn's authority by continued participation and that full payment was an unproven conclusion. After recall of the first entry of judgment and denial of reconsideration as late, a second Entry of Judgment issued on May 16, 2012. The Register of Deeds, asked to implement the January 4, 2011 Order, elevated by consulta whether the NLRC could order cancellation of Taguig Land's title and whether the order affected the two-thirds shares of non-party prior owners.

• Writ of Execution: Petitioner insisted that the January 4, 2011 Order should not be implemented or registered without a writ of execution, and that the May 16, 2012 Entry of Judgment could not dispense with that requirement for a final order.
• Denial of Execution: Petitioner argued that the CA gravely disregarded the LA's June 19, 2015 Order denying respondents' motion for execution directing cancellation of TCT No. 12619, which showed want of basis for registration.
• Quieting of Title and Injunction: Petitioner maintained that the CA overlooked its RTC complaint for quieting of title and the injunction issued therein recognizing its better right over the subject lot by virtue of its evidence.

• Legality of LRA and CA Rulings: Respondents propounded that the LRA Resolution and CA Decision were in full accord with law and jurisprudence and presented no reversible error.
• Ownership and Third-Party Claim: Respondents stressed that ownership had been settled in their favor and that petitioner's third-party claim over the subject lot had likewise been denied in a separate action.

• Registrability vs. Writ of Execution: Whether the January 4, 2011 LA Order as affirmed could be declared registrable by the LRA in consulta despite the absence of a writ of execution.
• Finality, Timeliness, and Immutability: Whether the CA correctly sustained the LRA in light of the entries of judgment, the belated Rule 43 appeal, and the doctrine of immutability of judgments.
• Collateral Proceedings: Whether the subsequent denial of a motion for execution and the pending quieting-of-title injunction precluded a declaration of registrability.

• Registrability vs. Writ of Execution: No error. Registrability is distinct from actual registration and cancellation of title; the consulta merely pronounced the final order registrable and did not dispense with execution for actual cancellation.
• Finality, Timeliness, and Immutability: Affirmed. The Rule 43 petition was filed 11 days late without justification, and the January 4, 2011 Order had become final, executory, immutable and unalterable, with no proven exception.
• Collateral Proceedings: No bar. Neither the later execution incident nor the RTC injunction overcame finality or the ministerial duty to register flowing from the conclusive consulta.

• Registrability vs. Writ of Execution: A writ of execution under the NLRC Manual is indispensable to enforce final NLRC or LA decisions, issuable only on a finally disposing order after furnishing copies and generally within five years from finality, with the Rules of Court applying only suppletorily and regular courts lacking jurisdiction over enforcement incidents. Applied here, no writ had yet issued because finality had just attached via the May 16, 2012 Entry of Judgment, but the consulta did not purport to execute or register title; it only declared the January 4, 2011 Order together with entry of judgment registrable. Actual registration remains the statutory duty of the Register of Deeds under Presidential Decree No. 1529, while the LRA assists courts and agencies and acts as central repository, resolving doubts via consulta under Section 117.
• Finality, Timeliness, and Immutability: Consulta rulings become conclusive and binding on Registers of Deeds if not appealed to the Court of Appeals within the period under Republic Act No. 5434 and Batas Pambansa Blg. 129 as implemented by Rule 43 — 15 days from notice, or 10 days from denial of a timely reconsideration, with only one reconsideration allowed and perfection being mandatory and jurisdictional. DMCI received denial of its LRA reconsideration on October 4, 2013, giving until October 19, 2013, but filed only on October 31, 2013 without explanation or extension motion, rendering the consulta final and obligating ministerial registration. Independently, the May 16, 2012 Entry of Judgment made the labor order final and immutable, unalterable even to correct alleged errors, none of the narrow exceptions — clerical correction, nunc pro tunc without prejudice, void judgment, or supervening unjust execution — having been raised and proven; attacking execution could not circumvent finality, particularly where DMCI's ownership claim had already been finally rejected in 2009.
• Collateral Proceedings: The later June 19, 2015 denial of execution and the RTC quieting-of-title injunction did not dissolve finality, the law of the case standing despite claims of error and indirect attacks being prohibited. The LRA's September 26, 2013 denial cured any reference to the recalled July 19, 2011 entry by relying on the May 16, 2012 entry, between which no inequitable supervening change was shown, and the second entry rendered any debate over the first moot.

• Ministerial duty of registration — Registration is a mere ministerial act inscribing the deed, contract, or instrument and annotating the certificate of title to give notice to all persons; it neither adds to validity nor converts an invalid instrument into a valid one, and the officer has no discretion to refuse a compliant instrument. Applied to require the Register of Deeds to register the final LA order once the consulta became conclusive.
• Consulta to the LRA — When in doubt on the proper step or memorandum for an instrument presented for registration, or when a party disagrees with the Register of Deeds, the question shall be certified to the LRA Commissioner who, after notice and hearing, prescribes the step to be taken; the ruling is conclusive and binding on all Registers of Deeds unless timely appealed to the Court of Appeals. Applied to sustain Consulta No. 5208 declaring the labor order registrable.
• Registrability distinguished from registration — A declaration that property is registrable means a party may register it in his or her name, while registration is the act itself of cancellation and issuance of title. Applied to reject the claim that a writ of execution for cancellation was a prerequisite to declaring registrability.
• Execution of NLRC judgments — The NLRC Manual governs execution, defining a writ of execution as the sheriff's authority valid for 180 days from receipt, issuable only upon a finally disposing order, resolution, or decision after due furnishing of copies, motu proprio or on motion within five years from finality and generally only when the records including entry of judgment are possessed. Applied to explain why absence of a writ did not defeat registrability at the consulta stage.
• Perfection of appeal as mandatory and jurisdictional — The right to appeal is a statutory privilege; Rule 43 requires filing within 15 days from notice or denial of the single allowed reconsideration, extendible only on proper motion, and non-compliance warrants dismissal and renders the judgment final and executory. Applied to DMCI's 11-day-late filing without justification or extension.
• Immutability of final judgments — A decision that has acquired finality becomes immutable and unalterable and may no longer be modified even to correct errors of fact or law, whether by the rendering court or the highest court, except for clerical corrections, nunc pro tunc entries causing no prejudice, void judgments, and supervening circumstances making execution unjust and inequitable. Applied to bar relitigation of ownership and to treat the labor award as law of the case.
• Redemptioners under NLRC execution — Only the losing party or successor-in-interest in the whole or part of the property, and a creditor with a lien by attachment, judgment, or mortgage subsequent to the judgment under which the property was sold, may redeem. Applied to hold DMCI, which claimed only through merger with a later transferee and showed no lien, was not a valid redemptioner.
• Quitclaims disfavored — Quitclaims and releases by laborers are jurisprudentially disfavored as contrary to public policy. Cited by the Labor Arbiter to support nullification of the Deed of Sale and/or Certificate of Redemption and Release and Quitclaim.

• "Registration is a mere ministerial act by which a deed, contract, or instrument is sought to be inscribed in the records of the Office of the Register of Deeds and annotated at the back of the certificate of title covering the land subject of the deed, contract, or instrument. Being a ministerial act, it must be performed in any case." — States the controlling definition of registration that deprived the Register of Deeds of discretion and obligated registration once the consulta became final.
• "In this regard, petitioner needs to be reminded that "registrability" and actual registration of real estate are very distinct concepts." — Articulates the decisive distinction that a consulta declaration does not itself cancel title and therefore needs no prior writ of execution.
• "Under the doctrine of finality of judgment or immutability of judgment, a decision that has acquired finality becomes immutable and unalterable, and may no longer be modified in any respect, even if the modification is meant to correct erroneous conclusions of fact and law, and whether it be made by the court that rendered it or by the Highest Court of the land." — States the canonical immutability rule barring DMCI's indirect attack on the final labor order.
• "To stress, the right to appeal is merely statutory and one who seeks to avail of it must comply with the statute or rules." — Grounds the dismissal effect of DMCI's belated Rule 43 petition and the finality of the LRA consulta.

• Tanongon vs. Samson, 431 Phil. 729 (2002) — Followed as authority that the NLRC has sufficient power to execute final judgments and awards and that third-party ownership claims do not necessarily prevent execution.
• Armed Forces and Police Mutual Benefit Association, Inc. vs. Santiago, 578 Phil. 609, 620 (2008) — Followed for the rule that Register of Deeds functions are generally ministerial without power to pass on legality of a court order, supporting registrability of the whole levied property.
• Office of the Ombudsman vs. Manalastas, 791 Phil. 557 (2016) — Followed to define registration as ministerial and to explain its notice purpose without curing invalidity.
• Saint Louis University, Inc. vs. Cobarrubias, 640 Phil. 682, 689 (2010) — Applied to warn that non-compliance with Rule 43 reglementary periods is sufficient ground for dismissal.
• Apex Mining Co., Inc. vs. Commissioner of Internal Revenue, 510 Phil. 268 (2005) — Followed that appeal periods are inviolable and perfection is mandatory and jurisdictional, with finality favoring the prevailing party.
• Vargas vs. Cajucom, 761 Phil. 43, 54 (2015) — Followed that a final judgment is law of the case and that what cannot be done directly may not be done indirectly by assailing execution.
• Gadrinab vs. Salamanca, 736 Phil. 279, 292-293 (2014); FGU Insurance Corporation vs. RTC, 659 Phil. 117, 123 (2011) — Reiterated for the immutability doctrine and its four narrow exceptions.
• Veloso vs. Department of Labor and Employment, 277 Phil. 230 (1991) — Cited by the Labor Arbiter for disfavor toward quitclaims and releases as contrary to public policy.
• Balais vs. Velasco, 322 Phil. 790, 807 (1996); Ando vs. Campo, 658 Phil. 636, 641-642 (2011) — Followed that regular courts lack jurisdiction over incidents of labor execution and that split jurisdiction is obnoxious to orderly justice.
• Mercury Drug Corporation vs. Spouses Huang, 817 Phil. 434, 437 (2017) — Followed that parties cannot circumvent immutability by merely assailing execution.

• Section 10, Presidential Decree No. 1529 — Imposes the Register of Deeds' ministerial duty to immediately register a compliant instrument bearing proper documentary stamps; applied to obligate registration following the final consulta.
• Section 117, Presidential Decree No. 1529 — Governs consulta procedure for doubtful registration questions and appeals to the Court of Appeals; applied to sustain elevation to the LRA and the binding effect of its ruling.
• Section 6(2), Presidential Decree No. 1529 — Defines LRA functions to assist agencies and courts and to serve as central repository of Torrens records; applied to distinguish LRA's role from actual registration.
• Section 4(b), Rule I and Section 4, Rule III, NLRC Manual on Execution of Judgment — Define writ of execution, its 180-day validity, issuance only on finally disposing orders, and five-year issuance window; applied to hold a writ indispensable for enforcement but not for a registrability declaration.
• Section 11, Rule VII, NLRC Manual on Execution of Judgment — Limits redemption to losing party or successor-in-interest and lien creditors subsequent to the judgment; applied to disqualify DMCI as redemptioner.
• Section 15, Rule VII, 2011 NLRC Rules of Procedure — Allows reconsideration only for palpable or patent errors filed within ten calendar days, only once; applied to deny DMCI's late reconsideration.
• Section 3, Rule I, 2011 NLRC Rules of Procedure — Provides suppletory application of the Rules of Court to effectuate labor justice when practicable; applied to deny regular-court interference.
• Section 2, Republic Act No. 5434; Section 9(3), Batas Pambansa Blg. 129; Sections 1 and 4, Rule 43, Rules of Court — Vest the Court of Appeals with exclusive appellate jurisdiction over LRA quasi-judicial rulings and fix the 15-day appeal period; applied to declare DMCI's petition belated and the consulta final.
• Article 1919, New Civil Code — Extinguishes agency upon accomplishment of its object or purpose; invoked by DMCI to challenge Evelyn's authority after alleged collection.

Leonen (Chairperson), Lazaro-Javier, M. Lopez, and Kho, JJ., concur.