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Manotok v. Heirs of Barque

CASE TITLE: Manotok IV, et. al. v. Heirs of Barque, G.R. Nos. 162335 & 162605, December 12, 2005
FACTS: The respondents, as the surviving heirs of the late Homer Barque, filed a petition with the Land
Registration Authority (LRA) for administrative reconstitution of the original copy of TCT No. 210177 issued
in the name of Homer L. Barque, which was destroyed in the fire that gutted the Quezon City Hall, including
the Office of the Register of Deeds of Quezon City, sometime in 1988. In support of the petition, petitioners
submitted the owner's duplicate copy of TCT No. 210177, real estate tax receipts, tax declarations and the
Plan FLS 3168 D covering the property. Upon being notified of the petition for administrative reconstitution,
petitioners filed their opposition, claiming that the lot covered by the title under reconstitution forms part of
the land covered by their reconstituted title, and alleging that TCT in the name of respondents'
predecessors-in-interest is spurious. The reconstituting officer, denied Barques' petition declaring that land
covered in the TCT is already registered in the name of the Manotoks and covered by another TCT which
was already reconstituted and that submitted plans by Barques’ was spurious. The Barques' motion for
reconsideration having been denied, they appealed to the LRA. The LRA reversed the ruling of the
reconstituting officer and declared that the Manotok title was fraudulently reconstituted. It ordered that
reconstitution of TCT No. 210177 in the name of Homer L. Barque shall be given due course after
cancellation of TCT No. RT-22481 (372302) in the name of the Manotoks upon order of a competent court
of jurisdiction. The LRA denied the Manotoks' motion for reconsideration and the Barques' prayer for
immediate reconstitution. Both the Manotoks and the Barques appealed the LRA decision to the CA, both
request were denied. From the foregoing, respondents filed a petition for review with the Court of Appeals
which affirmed the decision of the LRA. However, special division of CA gave conflicting resolutions. Hence,
the petition before the Supreme Court. The petition in G.R. No. 162605 was consolidated with the petition
in G.R. No. 162335.
ISSUE: Whether or not the Land Registration Authority has jurisdiction to rule on the validity of Manotok,
et al.'s title.
HELD: Yes. The factual finding of the LRA that respondents' title is authentic, genuine, valid, and existing,
while petitioners' title is sham and spurious, as affirmed by the two divisions of the Court of Appeals, is
conclusive before this Court. It should remain undisturbed since only questions of law may be raised in a
petition for review under Rule 45 of the Rules of Court. Findings of fact of administrative bodies are
accorded respect, even finality by this Court and, when affirmed by the Court of Appeals, are no longer
reviewable except only for very compelling reasons. Basic is the rule that factual findings of agencies
exercising quasi-judicial functions are accorded not only respect but even finality, aside from the
consideration that this Court is essentially not a trier of facts. The LRA has the jurisdiction to act on petitions
for administrative reconstitution. It has the authority to review, revise, reverse, modify or affirm on appeal
the decision of the reconstituting officer. The function is adjudicatory in nature — it can properly deliberate
on the validity of the titles submitted for reconstitution. Logically, it can declare a title as sham or spurious,
or valid on its face. Otherwise, if it cannot make such declaration, then there would be no basis for its
decision to grant or deny the reconstitution. The findings of fact of the LRA, when supported by substantial
evidence, as in this case, shall be binding on the Court of Appeals.