### Facts:
The case originated from a petition for reconstitution filed on January 12, 2006, by spouses Luisa Abellanosa and Generoso Manalo, represented by Fil-Estate Properties, Inc. (FEPI), in response to the loss of Original Certificate of Title Nos. 7001 (963) and 7362. These documents were for two parcels of land in Lucena City, which were sold and subsequently developed, but the titles were presumed burned in a 1983 fire at Lucena City Hall. The spouses sought to reconstitute the lost titles, providing technical descriptions and sketch plans. After amendments to the petition, including a substitution of parties due to the original petitioners’ deaths, the Regional Trial Court (RTC) granted the petition for reconstitution.
The Republic of the Philippines, represented by the Solicitor General, appealed the RTC’s order, arguing that proper jurisdiction was not acquired due to insufficient notices and that the bases for reconstitution were improper. The Court of Appeals dismissed this appeal, leading the Republic to file a petition for review on certiorari under Rule 45 of the Rules of Court.
### Issues:
1. Whether or not the Court of Appeals erred in ruling that the RTC acquired proper jurisdiction over the case.
2. Whether or not there was a sufficient basis for the reconstitution of the titles.
### Court’s Decision:
The Supreme Court found the petition devoid of merit, affirming the decision of the Court of Appeals. It held that the amendments to the petition did not necessitate another posting and publication for jurisdictional purposes as they did not affect the nature of the action significantly. The Court further ruled that the bases for the reconstitution, including the plans and technical descriptions, aligned with the acceptable sources enumerated in Republic Act No. 26. Therefore, the RTC’s order for reconstitution was properly granted based on sufficient bases.
### Doctrine:
The decision reiterates the doctrine concerning the judicial reconstitution of Torrens titles under Republic Act No. 26, emphasizing the acceptable bases for reconstitution and the procedural requirements for jurisdiction over such cases. It underscores that jurisdiction, once acquired, continues until the case is resolved and that amendments not affecting the action’s nature do not necessitate further notices for jurisdictional purposes.
### Class Notes:
– **Judicial Reconstitution**: The restoration of lost or destroyed Torrens certificates in their original form and condition.
– **Republic Act No. 26**: Governs the reconstitution of lost or destroyed land titles in the Philippines, detailing acceptable bases and procedural requirements.
– **Action in Rem**: A proceeding against the thing itself rather than against specific individuals, requiring public notice to all parties interested.
– **Jurisdiction Principles**: Jurisdiction, once acquired, is not lost until the case is terminated; amendments to petitions that do not change the nature of the action do not necessarily require new notices for jurisdiction.
– **Acceptable Bases for Reconstitution**: Include owner’s duplicates, co-owner’s/mortgagee’s/lessee’s duplicates, certified or authenticated copies of the certificate or decree of registration, and any other document deemed sufficient by the court.
### Historical Background:
This case reflects the Philippine legal system’s approach to dealing with the loss of property titles, especially in situations where natural disasters or accidents result in the destruction of original documents. The procedural and substantive law surrounding the reconstitution of Torrens titles aims to ensure that rightful owners can re-establish their legal claims to properties while providing a clear and fair process for all parties potentially affected.
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