**Spouses Laburada v. Land Registration Authority**
## Facts
Petitioners Spouses Marciano and Erlinda Laburada applied for the registration of Lot 3-A, Psd-1372, located in Mandaluyong City, in Land Registration Case (LRC) No. N-11022. On January 8, 1991, the Regional Trial Court (acting as a land registration court) adjudged that the applicants had a registrable title over the land and ordered the issuance of the corresponding decree upon finality of the decision.
Upon finality of the decision, the trial court, upon petitioners’ motion, issued an order on March 15, 1991, directing the Land Registration Authority (LRA) to issue the corresponding decree of registration. However, the LRA refused, citing doubts about the possibility of Lot 3-A already being included in existing Torrens titles from previous cases (CLR Case Nos. 699, 875, and 917). Specifically, TCT No. 6595, issued for Lot 3-A and TCT No. 29337, issued for Lot 3-B.
Petitioners sought this court’s intervention through a petition for mandamus under Rule 65, to compel the LRA to issue the requested decree. The LRA, represented by the Solicitor General, argued that issuing a new decree might result in duplication of titles and that land already decreed in earlier cases cannot be registered again.
## Issues
1. Whether the LRA can be compelled by mandamus to issue a decree of registration under circumstances suggesting possible duplication of titles.
2. Whether the judgment in the registration case is final and executory.
3. Whether the LRA’s role in issuing the decree is considered a ministerial act subject to a writ of mandamus.
## Court’s Decision
### 1. Compelling LRA through Mandamus
**Legal Issue:** Petitioners argued that mandamus should apply, contending that LRA unlawfully neglected its duty to issue the decree considering the trial court’s finality judgment.
**Resolution:** The Court ruled that mandamus is inappropriate because it can only compel an act that is purely ministerial with a clear legal right, which in this case was non-existent due to procedural uncertainties and overlapping titles. Further, mandamus could not be used to direct the LRA to perform an act involving discretion and technical assessment.
### 2. Finality of the RTC Decision
**Legal Issue:** Whether the RTC’s decision to order the decree of registration was final and enforceable.
**Resolution:** The Court emphasized that a judgment in land registration does not become executory until one year after the entry of the final registration decree. Because no such decree had been issued pending LRA’s verification, the RTC decision did not meet the threshold for finality and enforceability.
### 3. Ministerial Nature of Issuing the Decree
**Legal Issue:** Whether issuing the decree is a ministerial act that the LRA can be compelled to perform.
**Resolution:** The Court clarified that issuing a decree of registration is not a ministerial act but involves judicial functions, including technical verifications. Therefore, the act cannot be compelled via mandamus. Moreover, issuing a decree over possibly already registered land would contradict the principles of the Torrens system, leading to potential duplication.
## Doctrine
**Established Principle:** A land registration judgment does not become final and executory until one year post-entry of the final decree. Issuance of the decree is not a ministerial act, and mandamus cannot compel discretionary acts associated with judicial or quasi-judicial functions.
## Class Notes
**Key Concepts:**
– **In Rem Proceedings:** Attachments on land rather than specific individuals; final decrees bind all parties.
– **Torrens System Policy:** Only one title should exist per parcel to maintain the system’s integrity. Duplication undermines public trust.
– **Mandamus:** Compels ministerial acts if a clear legal right exists; not applicable for discretionary judicial acts.
– **Finality Concept in Registration:** Judgment in land registration proceedings attains finality one year after the decree’s entry.
– **Rule 65 of Rules of Court:** Applies to mandamus petitions when there’s unlawful neglect to fulfill a duty of the law.
**Essential Statutory Provisions:**
– **PD 1529 – Property Registration Decree**
– **Sec. 30:** Pertains to orders issued after judgment becomes final and executory.
– **Sec. 32:** Discusses the conclusive nature of decrees after the one-year statutory period.
## Historical Background
The case arose within the legal framework of the Torrens system implemented to provide a reliable, dispute-proof land registration system. The issue illuminates the procedural complexities and the judicial safeguards that ensure land titles are correctly and uniquely recorded, guarding against duplicative claims that could disrupt the order and trust intrinsic to property law in the Philippines.
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