Heirs of Dionisio Deloy and Praxedes Martonito Deloy vs. Verna R. Basa-Joaquin

An action to quiet title cannot prosper where the plaintiff's registered title traces from a reconstituted certificate of title that was void, unless the plaintiff proves acquisition in good faith and for value; tax declarations alone do not establish ownership. The Court also ruled that belated submission of proof of authority to sign the verification and certification against forum shopping is substantial compliance, and that a motion for new trial cannot be granted absent extrinsic fraud, accident, mistake, or excusable negligence.

Lot No. 4012 was originally registered in the names of siblings Dionisio Deloy and Isabel Deloy under TCT No. T-13784, with Dionisio occupying five hectares and Isabel one hectare. Dionisio sold portions of his share, leading to the subdivision of the lot and the eventual reconstitution of the original certificate after its original copy was lost in a fire in June 1959. The reconstituted title and the derivative certificates issued from it became the source of conflicting claims among Dionisio's heirs and subsequent purchasers. The present case is an offshoot of prior litigation that invalidated the reconstituted title and certain certificates issued in the name of the Province of Cavite.

Siblings Dionisio Deloy and Isabel Deloy were the registered owners of Lot No. 4012, a six-hectare parcel located at the Sta. Cruz de Malabon Estate, City of Trece Martires, Province of Cavite, covered by Transfer Certificate of Title No. T-13784. Dionisio occupied five hectares while Isabel occupied one hectare. Dionisio sold portions of the lot that he occupied. One of the buyers, Tomasa Figueroa, filed a petition for the approval of the subdivision plan of Lot No. 4012, which the Court of First Instance of Trece Martires City approved on February 15, 1966. Lot No. 4012 was thus subdivided into 13 lots, denominated as Lot Nos. 4012-A through 4012-M.

The approved subdivision plan and the owner's duplicate copy of TCT No. T-13784 were submitted to the Office of the Register of Deeds of the Province of Cavite. The Register of Deeds informed Isabel and Dionisio that TCT No. T-13784 had to be reconstituted because its original copy was lost in a fire sometime in June 1959. TCT No. T-13784 was reconstituted as TCT No. (T-13784) RT 12612 in the names of Isabel, Spouses Daniel and Francisca Paredes, Tomasa, the Province of Cavite, and Spouses Dionisio and Praxedes Deloy, with their corresponding shares. Thereafter, TCT No. (T-13784) RT 12612 was cancelled and separate titles were issued, including TCT Nos. T-19127 and T-19128 in the name of the Province of Cavite for Lot Nos. 4012-A and 4012-B, and TCT Nos. T-19312, T-19313, and T-19314 in Dionisio's name for Lot Nos. 4012-J, 4012-K, and 4012-L, respectively.

Dionisio died in 1985. In 1989, his surviving spouse, Praxedes, discovered the issuance of titles in the Province of Cavite's name when she looked for the certificates of title for Lot Nos. 4012-A and 4012-B. Praxedes and the other heirs of Dionisio filed a case for Annulment of Torrens Title and Deed of Conveyance with Damages against the Province of Cavite and the Register of Deeds for the Province of Cavite, docketed as Civil Case No. TM-695. On February 5, 1998, the RTC rendered judgment in favor of Praxedes and the other heirs, declaring any deed of conveyance presented by the Province and the Register of Deeds null and void, declaring TCT Nos. T-19127 and T-19128 null and void, and ordering their cancellation. On appeal, the CA affirmed the RTC in its Decision dated August 23, 2001 in CA-G.R. CV No. 61119, and further directed the Register of Deeds to cancel the reconstituted TCT No. (T-13784) RT-12612 and re-issue a new one in its original form, without prejudice to the annotation of subsequent dealings thereon, subject to compliance with Section 51 of PD 1529 and other pertinent laws. After the decision became final and executory, the Register of Deeds cancelled TCT No. (T-13784) RT 12612 and issued TCT No. (T-13784) RT-12612) T-66696 in lieu thereof, and all certificates of title issued in the name of the Province of Cavite were cancelled.

Respondents claimed interests in three lots. Verna Basa-Joaquin alleged that her parents, Spouses Gregorio and Iluminada Basa, purchased Lot No. 4012-J from Dionisio in 1967; TCT No. T-19312 was cancelled and TCT No. T-25563 was issued in their names. On May 4, 1970, Verna purchased Lot No. 4012-J; TCT No. T-25563 was cancelled and TCT No. T-43159 was issued in her name, later renumbered as TCT No. (T-43159) T-8554 when the Register of Deeds for Trece Martires City was created. The Heirs of Maxima Guevarra alleged that Maxima purchased Lot No. 4012-K from Dionisio on July 21, 1967, and that TCT No. T-19313 was cancelled and TCT No. (T-25562) T-22749 was issued in lieu thereof. The Heirs of Spouses Mariano and Macaria Del Rosario alleged that the spouses purchased Lot No. 4012-L from Dionisio on April 24, 1968; TCT No. T-19314 was cancelled and TCT No. (T-29268) T-69602 was issued in lieu thereof.

On June 20, 2007, the Register of Deeds for Trece Martires City sent respondents a letter asking them to surrender the owner's duplicate copies of their respective titles for the purpose of annotating the adverse claim of the Heirs of Spouses Deloy. Respondents complied. The Heirs of Spouses Deloy also placed a notice on Lot Nos. 4012-J, 4012-K, and 4012-L stating that the lots were truly owned by Spouses Dionisio and Praxedes Deloy and were covered by TCT Nos. T-81201, T-81202, and T-81203, respectively, pursuant to the CA decision in CA-G.R. CV No. 61119 that became final on November 22, 2001. Subsequently, respondents' certificates of title were cancelled and new titles were issued in Dionisio's name: TCT No. T-81201 for Lot No. 4012-J, TCT No. T-81202 for Lot No. 4012-K, and TCT No. T-81203 for Lot No. 4012-L. These titles were later cancelled after the settlement of the Estate of Spouses Deloy, and TCT No. 82597 was issued in the name of the Heirs of Spouses Deloy on January 25, 2008.

Respondents then filed separate petitions for quieting of title or removal of cloud and damages with prayer for temporary restraining order and/or preliminary injunction before the RTC. Verna's petition was docketed as Sp. Proc. Case No. TMSCA-005-08, while the petition of the Heirs of Spouses Del Rosario and Heirs of Maxima was docketed as Sp. Proc. Case No. TMSCA-0008-07. The Heirs of Spouses Deloy answered, alleging that the Special Power of Attorney executed by Verna in favor of Maurino J. Salazar was ineffectual; that the cancellation of TCT No. (T-13784) RT 12612 should result in the cancellation of all titles derived from it under the Annulment Case; and that respondents' titles were spurious and should be cancelled. They asserted that the placement of the sign on the properties was an exercise of their right of ownership. The RTC later declared the Heirs of Spouses Deloy precluded from presenting their evidence due to their repeated failure to appear in court. The RTC found respondents to be the real and true owners of Lot Nos. 4012-J, 4012-K, and 4012-L and granted the quiet-title petitions. The CA affirmed, finding that respondents proved by preponderance of evidence that they had titles over the lots and that they had no duty to investigate hidden defects in the certificates of title possessed by Dionisio at the time they purchased the lots.

• Certificate Against Forum Shopping: Petitioners assailed the lack of authority of Maurino J. Salazar and Angelita G. Del Rosario-Zoleta to sign respondents' Verification and Certification Against Forum Shopping, arguing that the Special Powers of Attorney were ineffectual or not properly submitted.
• Motion for New Trial / Due Process: Petitioners argued that their and their counsel's failure to receive notices of the hearings for the presentation of their evidence constituted extrinsic or collateral fraud, accident, mistake, or excusable negligence, violating due process and justifying a new trial.
• Quieting of Title / Derivative Titles: Petitioners maintained that the cancellation of TCT No. (T-13784) RT 12612 in the Annulment Case required the cancellation of all titles derived from it, including respondents' titles, which they claimed were spurious; the notice and sign were an exercise of their right of ownership.

• Quieting of Title: Respondents filed petitions for quieting of title or removal of cloud and damages, alleging that the reconstitution affected the certificates of title issued in their respective names over Lot Nos. 4012-J, 4012-K, and 4012-L.
• Ownership by Purchase: Verna alleged that her parents purchased Lot No. 4012-J from Dionisio in 1967 and that she purchased it in 1970; the Heirs of Maxima alleged that Maxima purchased Lot No. 4012-K from Dionisio on July 21, 1967; and the Heirs of Spouses Del Rosario alleged that the spouses purchased Lot No. 4012-L from Dionisio on April 24, 1968.
• Validity of Titles: Respondents maintained that their respective certificates of title were valid and subsisting and that the cancellation of the reconstituted title did not invalidate their registered ownership over the lots.

• Certificate of Non-Forum Shopping: Whether the CA erred in finding that respondents substantially complied with the requirement of a certificate of non-forum shopping.
• Motion for New Trial: Whether the CA erred in upholding the RTC's denial of petitioners Heirs of Spouses Deloy's motion for new trial.
• Quieting of Title: Whether the CA erred in affirming the RTC's ruling to grant respondents' petitions to quiet title.

• Certificate of Non-Forum Shopping: No. The CA correctly found substantial compliance; belated submission of the original SPAs proving authority to sign the verification and certification was not fatal under Section 5, Rule 7 of the Rules of Court.
• Motion for New Trial: No. The CA did not err in upholding the denial; petitioners failed to establish extrinsic or collateral fraud, accident, mistake, or excusable negligence, and notice to one of several counsels is notice to all.
• Quieting of Title: Yes. The CA erred in affirming the grant of the petitions; respondents failed to prove legal or equitable title and the invalidity of the cloud because their certificates traced from a void reconstituted title and they did not prove valid acquisition by preponderance of evidence.

• Certificate of Non-Forum Shopping: Section 5, Rule 7 of the Rules of Court requires the filing of a certificate against forum shopping. Respondents submitted a Verification and Certification Against Forum Shopping, but petitioners assailed the lack of authority of the persons who signed it. Maurino signed for Verna, while Angelita signed for the Heirs of Spouses Del Rosario and Heirs of Maxima. Verna attached a photocopy of the SPA she executed together with the Acknowledgment issued by the Consulate General of the Philippines in San Francisco, California, and submitted the original copy when she filed her formal offer of evidence. The Heirs of Spouses Del Rosario and Maxima submitted the original copies of the SPAs in favor of Angelita when they formally offered their evidence. The Court ruled that belated submission of proof of authority to sign the verification and certification against forum shopping is substantial compliance with the requirement under the Rules of Court. The rules on verification and forum shopping should not be interpreted with absolute literalness as to subvert their ultimate objective of promoting the orderly administration of justice. In Torres vs. Republic, the Court clarified that strict compliance with the provisions on certification against forum shopping merely underscores its mandatory nature, such that the certification cannot altogether be dispensed with or its requirements completely disregarded. Thus, respondents' belated submission of the original SPAs was not fatal to their cause.

• Motion for New Trial: The RTC declared the Heirs of Spouses Deloy precluded from presenting their evidence due to their repeated failure to appear in court. A party declared in default may file a motion for new trial after judgment has been promulgated but before it attains finality. The grounds under Section 1, Rule 37 of the Rules of Court are: (1) fraud, accident, mistake, or excusable negligence which ordinary prudence could not have guarded against and by reason of which the aggrieved party has probably been impaired in his or her rights; or (2) newly discovered evidence which could not have been discovered with reasonable diligence and which, if presented, would probably alter the result. Petitioners argued that their and their counsel's failure to receive notices of the hearings for the presentation of their evidence was tantamount to extrinsic or collateral fraud, accident, mistake, or excusable negligence. The Court disagreed. Extrinsic or collateral fraud refers to any fraudulent act of the prevailing party in litigation committed outside the trial, where the defeated party is prevented from fully exhibiting his or her side by fraud or deception practiced by the opponent, such as keeping the party away from court, giving a false promise of compromise, or where an attorney fraudulently or without authority connives at the party's defeat. Petitioners did not allege that respondents committed any act that prevented them from participating in the case, or that their own counsels betrayed them. Accident pertains to something that occurred by chance, while mistake refers to mistake of fact and not of law and does not cover judicial errors by the trial court that can be corrected on appeal. Petitioners did not expound on how their purported failure to receive notices qualified as an accident or mistake. Negligence is excusable when it is so gross that ordinary diligence and prudence could not have guarded against it, and it must be imputable to the party-litigants and not to their counsel. Petitioners did not allege that they were negligent with respect to the case. The motion for new trial was actually grounded on the alleged violation of their right to due process for failure to receive notices. The affidavits of merit of Atty. Octava and Atty. Custodio stated that notices for the hearings scheduled on April 14, 2011, May 26, 2011, and June 16, 2011 were not served upon their law offices. However, Policarpio Deloy, the duly appointed representative of petitioners, did not deny receiving notices from the RTC in his affidavits of merit. Under Section 13, Rule 13 of the Rules of Court, proof of service must consist of specific records. In Civil Case No. TMSCA-005-08, the RTC Order dated May 26, 2011 did not indicate how it was served, while the RTC Order dated June 16, 2011 appeared to have been mailed to Atty. Custodio and Atty. Octava on June 30, 2011 and allegedly delivered to Atty. Custodio on July 6, 2011, but there was no proof of receipt for both orders. Similarly, there was no proof of receipt of the RTC Orders dated April 14, 2011 and June 16, 2011 in Civil Case No. TMSCA-0008-07. Nonetheless, the lack of proof of receipt was not enough basis to overturn the RTC Order dated August 16, 2011 declaring petitioners in default. Atty. Custodio moved for the postponement of the hearing on March 24, 2011 in Civil Case No. TMSCA-005-08 so that it may be scheduled jointly with Civil Case No. TMSCA-0008-07. The RTC previously issued an Order on March 19, 2011 in Civil Case No. TMSCA-0008-07 setting the hearing for petitioners' case on April 14, 2011. Neither petitioners nor their counsel denied receiving a copy of this Order, yet they did not appear on April 14, 2011 or offer any justification for their absence. Atty. Octava received a copy of the RTC Order dated August 16, 2011 in both cases notifying him that the Heirs of Spouses Deloy were precluded from presenting their evidence due to their repeated failure to appear. Although Atty. Octava argued that he would have filed a memorandum if he were ordered to do so, nothing prevented him from asking the court to allow him to file a memorandum for his clients. Petitioners likewise did not move to set aside the order declaring them in default. As for the lack of notice to Atty. Custodio, notice to one of the party's several counsels is notice to all counsels. Her lack of receipt was of no moment in light of Atty. Octava's receipt of a copy of the Order dated August 16, 2011. Petitioners cannot validly claim that the RTC did not give them the opportunity to be heard, and they offered no acceptable explanation for being remiss in protecting their interest. Their motion for new trial is bereft of merit.

• Quieting of Title: An action to quiet title is based on Article 476 of the Civil Code. The requisites are: (1) the plaintiff or complainant must have a legal or equitable title to or interest in the real property subject of the action; and (2) the deed, claim, encumbrance, or proceeding claimed to be casting cloud on his or her title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy. Legal title refers to registered ownership while equitable title refers to beneficial ownership. Respondents were the registered owners of Lot Nos. 4012-J, 4012-K, and 4012-L under TCT Nos. T-8554-TMC-08-1212, T-22749, and T-69602, respectively. But these certificates of title were cancelled after the Heirs of Spouses Deloy obtained a favorable ruling in the Annulment Case. The claim of the Heirs of Spouses Deloy was initially annotated on the certificates of title of respondents, and they were able to secure certificates of title in their names after the settlement of the Estate of Spouses Deloy. While only TCT Nos. T-19127 and T-19128 were declared null and void in the Annulment Case, the CA discussed the propriety of reconstitution and ordered the cancellation of the reconstituted title itself, TCT No. (T-13784) RT-12612, which lists the Province of Cavite as one of the owners of Lot No. 4012. Respondents derived their certificates of title from TCT Nos. T-19312, T-19313, and T-19314, which in turn were derived from TCT No. (T-13784) RT-12612. A reconstituted title that was issued through fraud, deceit, misrepresentation, or other machination cannot be the source of legitimate rights and benefits. Nonetheless, the validity of respondents' certificates of title may be upheld if it is shown that they obtained their title in good faith and for value. As stated in the CA Decision in the Annulment Case, Praxedes was not aware of any sale or transfer of any portions of the subject property in favor of third persons except those in favor of Spouses Paredes and Tomasa Figueroa, and a deed of donation in favor of Communications and Electricity Development over an area of 680 square meters. Even so, the CA did not rule on the validity of the sale of Lot Nos. 4012-J, 4012-K, and 4012-L in the Annulment Case. Only TCT Nos. T-19127 and T-19128, the certificates of title in the name of the Province of Cavite, were declared null and void as they were issued without any basis. With respect to the other transactions concerning Lot No. 4012, the CA explained that any deeds of transfer validly made and properly registered subsequent to the issuance of the title on April 21, 1959 should merely be annotations on the Memorandum of Encumbrances until the registrant-interested party pays the registration and transfer fees, taxes, and all necessary charges, and only then shall the reconstituted TCT be cancelled and new titles issued to the transferees in accordance with law. The CA recognized that there may have been valid transactions regarding Lot No. 4012 notwithstanding the erroneous reconstitution of TCT No. 13784, and that an innocent purchaser for value may acquire ownership over the property even if he or she traces his or her title from a reconstituted certificate of title that is null and void. The question was whether respondents were able to prove that they validly acquired ownership over Lot Nos. 4012-J, 4012-K, and 4012-L. Respondents offered copies of their TCTs as evidence of ownership, but these certificates cannot be relied upon to prove the validity of the transfer of ownership considering that they were derived from a void reconstituted title. Verna did not present a copy of any instrument evincing the sale of Lot No. 4012-J from Dionisio to her parents, or the sale from her parents to herself. She admitted during her testimony that there was no documentary proof of the sale between Dionisio and Spouses Basa. In addition, the tax declaration presented by Verna was for the year 2001, followed by a certification from the City Treasurer of Trece Martires City that real property tax was paid for the years 2006 to 2007. Tax declarations, by themselves, do not prove ownership, more so where Spouses Basa supposedly purchased the property in 1967 but real property taxes were only paid in 2001. The evidence presented by Verna was not enough to prove that Dionisio sold Lot No. 4012-J to her parents. The Court similarly found wanting the evidence of the sale of Lot Nos. 4012-K and 4012-L to Spouses Del Rosario and Maxima, respectively. The Heirs of Spouses Del Rosario and Heirs of Maxima formally submitted a certified Xerox copy of the Deeds of Absolute Sale with Dionisio, and Angelita identified the document in court. However, a copy thereof did not appear in the records. Aside from the Deeds of Absolute Sale, the Heirs of Spouses Del Rosario presented tax declarations in the name of Spouses Del Rosario and Maxima issued for the year 2001, and a certification from the City Treasurer that real property tax for the respective properties for the year 2007 had been paid. Tax declarations are not conclusive evidence of ownership. The dearth of evidence regarding Lot Nos. 4012-K and 4012-L, which were supposedly transferred in 1967 and 1968, respectively, rendered the existence of the sale doubtful. In sum, respondents were unable to prove that their predecessors-in-interest validly purchased Lot Nos. 4012-J, 4012-K, and 4012-L from Dionisio. Their petitions for quieting of title cannot be granted for lack of basis.

• Action to Quiet Title — Requisites — Under Article 476 of the Civil Code, an action to quiet title requires: (1) the plaintiff or complainant must have a legal or equitable title to or interest in the real property subject of the action; and (2) the deed, claim, encumbrance, or proceeding claimed to be casting cloud on the title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy. The Court applied this doctrine by holding that respondents' registered titles, though apparently valid, traced from a void reconstituted title and were not supported by proof of valid acquisition, so the quiet-title petitions lacked basis.

• Certificate Against Forum Shopping — Substantial Compliance — The belated submission of proof of authority to sign the verification and certification against forum shopping is substantial compliance with the requirement under the Rules of Court. The rules on verification and forum shopping should not be interpreted with absolute literalness as to subvert their ultimate objective of promoting and facilitating the orderly administration of justice. The Court applied this doctrine by ruling that respondents' original SPAs, submitted during their formal offer of evidence, cured the lack of authority of the signatories.

• Motion for New Trial — Grounds — Under Section 1, Rule 37 of the Rules of Court, the grounds for a motion for new trial are: (1) fraud, accident, mistake, or excusable negligence which ordinary prudence could not have guarded against and by reason of which the aggrieved party has probably been impaired in his or her rights; or (2) newly discovered evidence which could not have been discovered with reasonable diligence and which, if presented, would probably alter the result. Extrinsic or collateral fraud refers to a fraudulent act of the prevailing party committed outside the trial, preventing the defeated party from fully exhibiting his or her side. Accident pertains to something that occurred by chance; mistake refers to mistake of fact and not of law; and excusable negligence must be so gross that ordinary diligence and prudence could not have guarded against it and must be imputable to the party-litigants and not to their counsel. The Court applied this doctrine by finding that petitioners failed to establish any of these grounds.

• Notice to One of Several Counsels — Notice to one of a party's several counsels is notice to all the counsels. The Court applied this doctrine by holding that Atty. Custodio's lack of receipt of the RTC Order dated August 16, 2011 was of no moment because Atty. Octava, the collaborating counsel, received a copy of the same order.

• Void Reconstituted Title — A reconstituted title that was issued through fraud, deceit, misrepresentation, or other machination cannot be the source of legitimate rights and benefits. However, an innocent purchaser for value may acquire ownership over the property even if he or she traces his or her title from a reconstituted certificate of title that is null and void. The Court applied this doctrine by requiring respondents to prove that they obtained their titles in good faith and for value, and by finding that they failed to do so.

• Tax Declarations as Evidence of Ownership — Tax declarations, by themselves, do not prove ownership. The Court applied this doctrine by rejecting respondents' tax declarations, which were issued only in 2001, and tax payment certifications for 2006 to 2007, as insufficient to prove sales allegedly made in 1967 and 1968.

• "The Court has ruled that the belated submission of the proof of authority to sign the verification and certification against forum shopping is substantial compliance with the requirement under the Rules of Court." — This passage resolves the first issue by holding that respondents' late submission of the original SPAs was not fatal to their cause.
• "A reconstituted title that was issued through fraud, deceit, misrepresentation, or other machination cannot be the source of legitimate rights and benefits." — This states the core rule on void reconstituted titles, which the Court used to require proof of good faith and valid acquisition from respondents.
• "Nonetheless, the validity of TCT Nos. (T-43159) T-8554, (T-25562) T-22749, and (T-29268) T-69602, may be upheld if it is shown that respondents obtained their title in good faith and for value." — This qualifies the rule on void reconstituted titles by recognizing the exception for innocent purchasers for value.
• "In sum, respondents were unable to prove that their predecessors-in-interest validly purchased Lot Nos. 4012-J, 4012-K, and 4012-L from Dionisio. As such, their petitions for quieting of title cannot be granted for lack of basis." — This is the ultimate conclusion on the quiet-title issue, explaining why the CA was reversed and the petitions dismissed.

• Dizon vs. Matti, Jr., G.R. No. 215614 (Resolution), March 27, 2019 — Cited for the rule that belated submission of proof of authority to sign the verification and certification against forum shopping is substantial compliance.
• Torres vs. Republic, G.R. No. 247490, March 2, 2022 — Cited to clarify that strict compliance with the certification against forum shopping merely underscores its mandatory nature, meaning the certification cannot be dispensed with or its requirements completely disregarded.
• National Power Corp. vs. Baysic, G.R. No. 213893, September 25, 2019, citing David vs. Judge Gutierrez-Fruelda, 597 Phil. 354, 361 (2009) — Cited for the rule that a party declared in default may file a motion for new trial after judgment has been promulgated but before it attains finality.
• Santos vs. Santos, G.R. No. 214593, July 17, 2019, citing Lasala vs. National Food Authority, 767 Phil. 285, 301 (2015) — Cited for the definition of extrinsic or collateral fraud as a ground for new trial.
• City of Dagupan vs. Maramba, 738 Phil. 71, 91 (2014) — Cited for the rules that mistake refers to mistake of fact and not of law, and that excusable negligence must be so gross that ordinary diligence and prudence could not have guarded against it.
• Phil. Asset Growth Two, Inc. vs. Fastech Synergy Phils., Inc., 788 Phil. 355, 372 (2016) — Cited for the rule that notice to one of a party's several counsels is notice to all counsels.
• Gatmaytan vs. Misibis Land, Inc., G.R. No. 222166, June 10, 2020 — Cited for the requisites of an action to quiet title under Article 476 of the Civil Code.
• National Housing Authority vs. Laurito, 814 Phil. 1019, 1037 (2017); Eastworld Motor Industries Corp. vs. Skunac Corp., 514 Phil. 605, 613-614 (2005) — Cited for the rule that a reconstituted title issued through fraud, deceit, misrepresentation, or other machination cannot be the source of legitimate rights and benefits, and for the exception allowing an innocent purchaser for value to acquire ownership even from a void reconstituted title.
• Muñoz vs. Yabut, Jr., 665 Phil. 488 (2011) — Cited for the rule that the validity of a certificate of title derived from a void reconstituted title may be upheld if it is shown that the holder obtained title in good faith and for value.
• Heirs of Casiñio, Sr. vs. Development Bank of the Philippines, Malaybalay Branch, Bukidnon, G.R. Nos. 204052-53, March 11, 2020 — Cited for the rule that tax declarations, by themselves, do not prove ownership.

• Article 476, Civil Code — Defines an action to quiet title and provides that whenever there is a cloud on title to real property by reason of any instrument, record, claim, encumbrance, or proceeding which is apparently valid but in truth invalid, ineffective, voidable, or unenforceable, an action may be brought to remove such cloud or quiet the title. The Court applied this provision by requiring respondents to prove legal or equitable title and the invalidity of the cloud, which they failed to do.
• Section 5, Rule 7, Rules of Court — Requires the plaintiff or principal party to certify under oath in the complaint or initiatory pleading, or in a sworn certification annexed thereto, that he or she has not commenced any action or filed any claim involving the same issues, and to report any similar pending action. The Court applied this provision by ruling that respondents substantially complied despite the belated submission of the original SPAs.
• Section 1, Rule 37, Rules of Court — Provides the grounds for a motion for new trial: fraud, accident, mistake, or excusable negligence, or newly discovered evidence. The Court applied this provision by finding that petitioners failed to establish any of the grounds.
• Section 13, Rule 13, Rules of Court — Defines proof of service, including personal service, ordinary mail, and registered mail. The Court applied this provision by examining the lack of proof of receipt of the RTC Orders and concluding that it was not enough to overturn the order declaring petitioners in default.

Justice Caguioa (Chairperson), Senior Associate Justice Leonen, Justice Gaerlan, and Justice Singh concurred.