Angeles Vs Sec. of Justice 1111
Angeles Vs Sec. of Justice 1111
Angeles Vs Sec. of Justice 1111
of Justice
GR No. 142549, March 9, 2010
Facts: The property involved in this case is covered by Original Certificate of Title (OCT) No. 994, which
encompasses One Thousand Three Hundred Forty-Two (1,342) hectares (area larger than the sovereign states of
Monaco and the Vatican). What we have before us now is touted as "one of the biggest and most extensive land-grabbing incidents in
recent history.
On May 3, 1965, petitioner Angeles, et.al, are claiming to be the heirs of Maria de la Concepcion Vidal, and
alleging that they are entitled to inherit her proportional share in the parcels of land, filed for a partition and
accounting of the property otherwise known as Maysilo Estate covered by OCT No. 994, allegedly registered on
April 19, 1917 with the Registry of Deeds of Caloocan City.
Some of said alleged heirs were able to procure TCTs over portions of the Maysilo Estate. They also had led this
Court to believe that OCT No. 994 was registered twice. Hence, the Court held that OCT No. 994 dated April
19, 1917, and not May 3, 1917, was the valid title by virtue of the prior registration rule.
The ROD of Caloocan City and of Quezon City are hereby directed to issue transfer certificates of title in the
names of all the co-owners for the following lots. But the LRA Administrator contends that :
There is only one (OCT) No. 994 and this was issued or registered on May 3, 1917
That the OCT dated April 19, 1917 was a fabrication of Norberto Vasquez (Former Deputy of RD Caloocan)
That the heirs are not the true heirs of Concepcion Vidal (physical and genetic impossibility)
That former RD of Caloocan, Yolanda Alfonso and Vasquez acted in bad faith issuing TCT to Rivera with fully
knowing it was derived from the fraudulent OCT dated on April 17.1917 .
Respondent Guingona contends that it can be gleaned from the purpose of the creation of the committee that its
fact-finding investigation was merely administrative to formulate and recommend policies, procedures and
courses of action which the DOJ, the LRA, the Office of the Solicitor General and other agencies of the DOJ
can adopt with regard to the problem of the proliferation of fake land titles, including those that relate to the
Maysilo Estate.
Petitioner contends that former DOJ Secretary Guingona has to be named as private respondent because he was
the cause of public respondents’ failure to comply with their ministerial duty.
Issue: Whether public respondents unlawfully neglected to perform their duties by their refusal to issue the
transfer certificates of title to petitioner?
It was not unlawful for public respondents to refuse compliance with the RTC Order. Rather than a
sign of negligence in the performance of its duty, the LRA's reaction is reasonable, even imperative.
Considering the probable duplication of titles over the same parcel of land, such issuance may
contravene the policy and the purpose, and thereby destroy the integrity, of the Torrens system of
registration.
The issuance of the LRA of a decree of registration is not purely ministerial in cases where it would
result to doubling of titles for the same parcel of land. Neither could respondent LRA Administrator be
mandated by the Court to require the Register of Deeds to comply with said Order, for we find merit in
the explanations of respondent LRA.
There was, therefore, sufficient basis for public respondents to refuse to comply with the RTC Order,
given the finding, contained in the cited documents, that OCT No. 994 dated April 19, 1917, on which
petitioner and her co-plaintiffs in the civil case clearly anchored their rights, did not exist. The court
categorically concluded that "OCT No. 994 which reflects the date of 19 April 1917 as its registration
date is null and void. The partition and accounting of a portion of the Maysilo Estate, can no longer
prosper because the very basis of their claim 1st registration of OCT No. 994, does not exist.