The Supreme Court affirmed that there is no time limit to re-issue a land registration decree, even decades after its initial issuance. This means property owners with valid decrees can still obtain their Original Certificates of Title (OCTs), regardless of how much time has passed. This ruling confirms that land ownership, once judicially declared, stands firm against prescription or the statute of limitations, ensuring that property rights established long ago are still enforceable today.

Can a Land Title, Once Decreed, Be Lost to the Sands of Time?

This case revolves around Claro Yap’s petition to re-issue Decree No. 99500, which covered Lot No. 922 in Carcar, Cebu, originally issued in 1920. Yap sought this re-issuance to obtain an Original Certificate of Title (OCT) for the land, claiming ownership through inheritance, donation, and continuous possession since 1945. However, the Republic of the Philippines, represented by the Office of the Solicitor General (OSG), opposed the petition, arguing that Yap’s claim was barred by prescription, given the long lapse since the original decree. The OSG also argued a lack of evidence and the failure to include indispensable parties, such as the heirs of Juan Rodriguez and/or Andres Abellana.

The Regional Trial Court (RTC) and the Court of Appeals (CA) both ruled in favor of Yap, prompting the Republic to elevate the case to the Supreme Court. At the core of this legal battle lies the question: Can a land registration decree, once issued, be subject to prescription? The Supreme Court was tasked with determining whether the RTC correctly ordered the cancellation and re-issuance of Decree No. 99500, and the issuance of the corresponding OCT. In answering this, the Supreme Court addressed the interplay between property rights, procedural rules, and the passage of time.

The Supreme Court firmly rejected the OSG’s argument that Yap’s petition was barred by prescription. The Court emphasized that prescription cannot be raised for the first time on appeal, and more importantly, that prescription does not apply to land registration cases. The Court cited the landmark case of Sta. Ana v. Menla, which established that statutes of limitations and rules on execution of judgments in civil actions do not apply to special proceedings like land registration. In land registration, the goal is to establish ownership, and once ownership is judicially confirmed, no further action is needed to enforce it, unless the adverse party is in possession.

There is nothing in the law that limits the period within which the court may order or issue a decree. The reason is what is stated in the consideration of the second assignment error, that the judgment is merely declaratory in character and does not need to be asserted or enforced against the adverse party.

Building on this principle, the Supreme Court highlighted that the issuance of a decree is a ministerial duty of the court and the Land Registration Authority. Failure to issue a decree due to lack of motion cannot prejudice the owner. This principle was further solidified in Heirs of Cristobal Marcos v. de Banuvar and Ting v. Heirs of Diego Lirio, reinforcing that a final judgment confirming land title constitutes res judicata against the whole world, and the adjudicate need not file a motion to execute it. In essence, the judicial confirmation of land ownership stands the test of time.

The Court also addressed the OSG’s argument regarding the lack of evidence. It reiterated that Yap had sufficiently proven the issuance of Decree No. 99500 in 1920 and the absence of an OCT for Lot No. 922. The Court referenced Section 39 of Presidential Decree No. 1529, the Property Registration Decree, which mandates that the original certificate of title be a true copy of the decree of registration. This necessitates the cancellation of the old decree and the issuance of a new one to ensure both documents are exact replicas.

Furthermore, the Court cited Republic v. Heirs of Sanchez, emphasizing the necessity of petitioning for the cancellation of the old decree and its re-issuance when no OCT had been issued. According to the Supreme Court:

Under the premises, the correct proceeding is a petition for cancellation of the old decree, re-issuance of decree and {or issuance of OCT pursuant to that re-issued decree.

The Republic in Republic v. Heirs of Sanchez also stated: “The original certificate of title shall be a true copy of the decree of registration.” This provision is significant because it contemplates an OCT which is an exact replica of the decree. If the old decree will not be canceled and no new decree issued, the corresponding OCT issued today will bear the signature of the present Administrator while the decree upon which it was based shall bear the signature of the past Administrator. This is not consistent with the clear intention of the law which states that the OCT shall be true copy of the decree of registration. Ostensibly, therefore, the cancellation of the old decree and the issuance of a new one is necessary.

Therefore, the RTC’s order to cancel Decree No. 99500, re-issue it, and issue the corresponding OCT in the name of Andres Abellana, as Administrator of the Estate of Juan Rodriguez, was deemed correct. The Supreme Court found no reason to overturn the CA’s decision, as the Republic failed to show any arbitrariness or disregard of evidence.

This ruling reaffirms the enduring validity of judicially decreed land titles. It clarifies that the passage of time does not diminish the right to obtain an OCT based on a valid decree. This decision provides security to landowners, assuring them that their property rights, once legally established, remain enforceable regardless of delays in obtaining the corresponding certificate of title. It underscores the importance of the Torrens system in ensuring indefeasibility of titles, protecting landowners from potential claims based on prescription or laches.

Ultimately, this case serves as a reminder of the enduring nature of property rights in the Philippines. It affirms that judicial decrees are not subject to the same limitations as ordinary civil actions, and that landowners can rely on the validity of their decrees to secure their titles, even after significant periods of time. This decision promotes stability and predictability in land ownership, reinforcing the integrity of the Torrens system. This contrasts sharply with systems that allow property claims to be extinguished by the mere passage of time, regardless of the validity of the original title.

This case provides a solid foundation for property owners seeking to formalize their land titles based on old decrees. It also serves as a warning to potential adverse claimants, clarifying that the principle of prescription cannot override a judicially confirmed land title. The Supreme Court’s decision reinforces the importance of adhering to legal processes in land ownership and the enduring validity of decrees issued by competent courts. This adherence ensures that the rights of landowners are protected, fostering confidence in the land titling system. The Supreme Court, through this decision, provided clarity and stability to the land registration system in the Philippines.

FAQs

What was the key issue in this case?	The central issue was whether a petition to re-issue a land registration decree and obtain an Original Certificate of Title (OCT) could be barred by prescription decades after the decree was initially issued.
What did the Supreme Court rule?	The Supreme Court ruled that prescription does not apply to land registration cases. Thus, there is no time limit to re-issue a land registration decree to obtain an OCT.
What is an Original Certificate of Title (OCT)?	An OCT is the first title issued for a piece of land registered under the Torrens system. It serves as the root document proving ownership of the land.
What is a land registration decree?	A land registration decree is a court order confirming the ownership of a piece of land and directing its registration. It forms the basis for issuing an OCT.
What is the Torrens system?	The Torrens system is a land registration system where the government guarantees the accuracy of land titles. This system helps prevent disputes and ensures the indefeasibility of titles.
What is prescription in legal terms?	In legal terms, prescription refers to the acquisition or loss of rights due to the passage of time. However, the Supreme Court clarified that prescription does not apply to land registration cases.
Why was the re-issuance of the decree necessary in this case?	The re-issuance was necessary because no OCT had ever been issued based on the original decree. The new decree serves as the basis for issuing an OCT.
Can heirs file a petition for re-issuance of a decree?	Yes, the heirs of the original adjudicate (person awarded the land) can file the petition. The re-issued decree will still be in the name of the original adjudicate.
What is the significance of this ruling for landowners?	This ruling provides security to landowners, assuring them that their property rights, once legally established, remain enforceable regardless of delays in obtaining the corresponding certificate of title.
What is res judicata?	Res judicata is a legal doctrine preventing the same parties from relitigating issues that have already been decided by a competent court. In this case, it means the court’s approval of land registration settles its ownership and is binding on the whole world.

The Supreme Court’s decision in Republic vs. Yap reinforces the stability and reliability of the Philippine land registration system. By affirming that decrees do not expire, the Court protects the rights of landowners and provides clarity on the process of obtaining land titles. This ensures a more secure and predictable environment for property ownership in the Philippines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Republic of the Philippines vs. Claro Yap, G.R. No. 231116, February 07, 2018