Civil Law

Philippine Cotton Corporation vs Naraindas Gagoomal

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544 SCRA 185 – Civil Law – Land Titles and Deeds – Reconstitution of Land Title – Annotation by the Registry of Deeds

The Pacific Mills Corporation owned 5 parcels of land in Quezon City covered by four certificates of title. Pacific Mills sold the land to Naraindas Gagoomal and Engracio Ang in 1979.

In 1983, Philippine Cotton Corporation won a case in the lower court against Pacific Mills which led to the attachment of the 5 parcels of land previously owned by Pacific Mills. Pacific Mills appealed until it reached the Supreme Court.

While the case was pending in the SC, the QC Registry of Deeds was razed by fire thereby destroying all records. In 1992, Pacific Mills filed for a reconstitution of land. It was granted but it was immediately cancelled in favor of Ang and Gagoomal. Subsequently, Ang and Gagoomal received clean TCTs.

Meanwhile, Philippine Cotton received a favorable judgment from the SC and they requested the Register of Deeds to annotate the same on the titles issued to And and Gagoomal. The Register of Deeds then annotated the said titles and then sent a letter to Ang and Gagoomal to surrender their duplicates.

Ang and Gagoomal petitioned for the removal of the annotation. Philippine Cotton argued that the RD can validly annotate a Supreme Court decision on the said titles and that the same is its ministerial duty.

ISSUE: Whether or not Philippine Cotton’s contention is correct.

HELD: No. Under the circumstances, the Registry of Deeds of Quezon City should and could have properly refused such request instead of immediately annotating it. In the same light, “The Register of Deeds may likewise properly refuse registration of an order of attachment when it appears that the title involved is not in the name of the defendant and there is no evidence submitted to indicate that the said defendant has any present or future interest in the property covered by the titles.”

Note that in the case won by Philippine Cotton before the SC, the defendant therein was Pacific Mills. Ang and Gagoomal acquired the property before the resolution of the case, hence, the annotation is not valid because Ang and Gagoomal were not parties to the said case.

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