Marilyn L. Go Ramos-Yeo, Laurence L. Go, and Montgomery L. Go vs. Spouses Richard O. Chua and Polly S. Chua, et al.; Multi-Realty Development Corporation vs. Marilyn L. Go Ramos-Yeo, et al.
### Facts:
1. **Property Dispute Origin**: Spouses Richard and Polly Chua filed a complaint for accion reinvindicatoria (recovery of real property) in the Regional Trial Court (RTC) of Tagaytay City against Marilyn L. Go Ramos-Yeo, Laurence Go, and Montgomery Go (collectively “the Gos”) and Multi-Realty Development Corporation (“Multi-Realty”).
2. **RTC Decision**: The RTC rendered an amended decision on January 27, 1992, in favor of the Chuas, altering the boundaries of the properties owned by the Gos and Multi-Realty.
3. **Proceedings at the Court of Appeals**: The Gos filed an Amended Petition for Annulment of Judgment on jurisdictional grounds, which the Court of Appeals (CA) denied, leading to a Decision on March 9, 2017, and a subsequent Resolution on October 24, 2017, upholding the RTC’s decision.
4. **Supreme Court Involvement**: The Gos elevated the matter to the Supreme Court (SC) via a Petition for Review on Certiorari under Rule 45. The SC found in favor of the Gos, reversing the CA’s decisions on November 5, 2018, based on invalid substituted service of summons and lack of jurisdiction over the subject matter, resulting in the RTC decision being null and void.
5. **Consolidated Motion for Reconsideration**: Spouses Chua filed a motion for reconsideration of the SC’s decision, which led to another review by the SC.
### Issues:
1. Whether the substituted service of summons on the Gos was properly effected.
2. Whether the RTC had jurisdiction over the subject matter of the accion reinvindicatoria.
3. Applicability of Sections 32 and 108, Presidential Decree No. 1529 concerning the finality of decrees of registration.
4. Whether there was a procedural error in the simultaneous promulgation of the SC’s Decision and Resolution including the directive for soft copy submissions.
### Court’s Decision:
1. **Improper Substituted Service**:
– **SC Ruling**: The SC concluded that the Deputy Sheriff Bienvenido Liboro failed to exert earnest efforts to personally serve summons to the Gos to justify substituted service.
– **Details**: The SC emphasized that substituted service requires attempting personal service three times or demonstrating valid reasons for its impracticability. No such attempts or justifications were evidenced, making the summons invalid and the RTC not acquiring jurisdiction over the persons of the Gos.
2. **Jurisdiction Over Subject Matter**:
– **SC Ruling**: The complaint for accion reinvindicatoria effectively sought to review and amend final decrees of registration, an authority exclusive to land registration courts.
– **Details**: Adjustments to the property boundaries altered due to the RTC’s decision violated PD 1529. Final decrees cannot be collaterally attacked or reviewed in ordinary civil courts.
3. **Incontrovertibility of Titles Under PD 1529**:
– **SC Ruling**: The titles conferred to the Gos and Multi-Realty were already incontrovertible as more than one year had passed since their registration.
– **Details**: Citing Sections 32 and 108 of PD 1529, the court held that these sections bar any collateral attack on title once a decree of registration has become final.
4. **Procedural Aspect – Resolution and Decision Promulgation**:
– **SC Ruling**: No procedural misstep occurred when the SC promulgated its Decision and Resolution on the same day.
– **Details**: The court received hard copies of all necessary comments before the date of resolution and decision, fulfilling requirements, and the subsequent soft copies submission was purely administrative for rules compliance, not affecting the court’s ability to resolve the case.
### Doctrine:
1. **Substituted Service**: Service of summons must adhere strictly to required steps and justifications for substituted service are strictly construed.
2. **Jurisdiction over Land Registration**: Only land registration courts have authority over amendments to final decrees of registration due to PD 1529 provisions.
3. **Incontrovertibility of Title**: Final decrees and certificates of registration cannot be challenged after a statutory period due to the public policy of stability of property ownership.
### Class Notes:
– **Substituted Service**: Attempts or justification for failure to personally serve summons must be adequately documented (Rule 14, Rules of Court).
– **PD 1529**: Sections 32 and 108 – Protects the finality and incontrovertibility of certificates of title post one year of decree.
– **Jurisdiction**: Civil actions impinging on registration decrees should fall under the jurisdiction of land registration courts.
### Historical Background:
This case reflects the stringent legal framework safeguarding the finality and certainty of land titles in the Philippines. It underscores the critical importance of adhering to procedural requisites in judicial processes and maintaining the jurisdictional boundaries set by statutory law. The ruling reiterates the necessity for proper service of summons as essential for jurisdiction and the inviolability of land titles post-registration under PD 1529.
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