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**Title:** Baguio Trinity Developers, Inc. v. The Heirs of Jose Ramos and the Heirs of Leopoldo and Victorina Nepa; and the Honorable Court of Appeals (G.R. No. 187189)
**Facts:**
1. Spouses Meliton Grabiles and Leona Calderon originally owned a 2,933-square-meter lot in Rosario, La Union.
2. This property underwent successive transfers, eventually sold to Baguio Trinity Developers, Inc. on January 3, 1994, and title T-38340 was issued in its name.
3. In 1985, Anastacio Laroco and Leona Javier filed a reconstitution proceeding before RTC Agoo, La Union, which resulted in the title being reconstituted in Maria Bernal’s name on October 20, 1986.
4. In 1986, Melicia Silva filed another reconstitution petition for the Grabiles’ title, and on October 28, 1986, the RTC reconstituted it in the name of Grabiles as OCT RO-4717. The title indicated it was sold to Jose Ramos and to Leopoldo and Victorina Nepa in subsequent transactions.
5. On September 14, 1995, Baguio Trinity filed a complaint at the MTC of Rosario, La Union for the nullification of the reconstituted titles, which was dismissed due to lack of jurisdiction.
6. On December 3, 1997, Baguio Trinity filed a similar complaint with the RTC of Agoo, Branch 32, which was dismissed on May 31, 2004, for lack of jurisdiction and for being unable to annul an order of a co-equal court.
7. An appeal to the CA was dismissed on September 13, 2007, advising that the proper remedy was a petition to annul the judgment under Rule 47.
8. On December 20, 2007, Baguio Trinity filed a petition for annulment of judgment with the CA. The CA dismissed it on May 8, 2008, due to failure to attach a certified true copy of the pertinent orders and for insufficient docket fees.
9. After remitting the lacking docket fees and further submissions, including the affidavit of Cresencio Aspiras, the CA denied the motion for reconsideration on November 7, 2008.
10. Subsequently, Baguio Trinity appealed to the Supreme Court of the Philippines.
**Issues:**
1. Whether the CA erred in dismissing the petition for annulment of judgment for failing to submit a certified true copy of the RTC’s reconstitution orders.
2. Whether the CA correctly barred the petition on the ground of laches.
**Court’s Decision:**
*On the issue of certified true copies:*
– The Supreme Court ruled that the CA erred in its interpretation of Rule 47. The loss of original documents due to the 1990 earthquake was a sufficient reason to accept secondary evidence.
– Consequently, the submission of copies from the Land Registration Authority (LRA) along with a verified statement was accepted as compliance with Rule 47.
– The CA was directed to proceed with adjudicating the case based on the merits of the documents provided.
*On the issue of laches:*
– The Supreme Court disagreed with the CA, finding that Baguio Trinity had not exhibited inaction but had been actively pursuing their case through appropriate legal avenues albeit misdirected by lower courts.
– The complexity of the issue, involving both legal misdirection and dual existing titles, warranted a resolution that laches could not obviate.
– Therefore, the action for annulment was not barred by laches and must be heard on the merits.
**Doctrine:**
– **Necessity of Certified True Copies:** While procedural rules mandate attaching certified true copies of the judgment or final orders, the absence due to loss allows for secondary evidence. Public officers’ certification of lost records and authenticated recitals suffice.
– **Laches and Active Pursuit:** An action is not barred by laches if continuous efforts to seek judicial remedy are evident. Simply being misdirected by lower courts does not amount to inaction.
**Class Notes:**
1. Elements of Reconstitution of Title:
– A petition filed for lost titles.
– Orders for reconstitution by the RTC.
– Notice requirements and documents for reconstitution.
2. Rule 47, Rules of Civil Procedure: Requires certified true copies of judgments or orders; however, loss permits the use of duly authenticated secondary evidence (Rule 130, Section 5).
3. Definition of Laches: Inaction or delay in asserting a right; exception includes continuous actions confused by procedural errors.
4. **LRA and Register of Deeds:** Act as secondary sources for certified true copies post the destruction of original documents.
**Historical Background:**
– Post-World War II and subsequent natural disasters, such as the 1990 earthquake, led to procedural adaptations in judicial documentation.
– Property rights and title reconstitution processes in the Philippines often become complex due to multiple transfers and loss of original documents, necessitating judicial reinterpretations.
**Cited Provisions:**
– **Rule 47, Rules of Civil Procedure:** Pertains to the annulment of judgments.
– **Section 5, Rule 130 of the Rules of Evidence:** Provisions on secondary evidence when originals are unavailable.
This case reaffirms the adaptability of procedural rules to ensure justice despite catastrophic losses and underlines the significance of persistent judicial pursuit in property litigation.
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