SPECIAL THIRD DIVISION
EAGLE REALTY CORPORATION, Petitioner, - versus - REPUBLIC
OF THE PHILIPPINES Represented by the Administrator of the Land Registration
Authority, NATIONAL TREASURER OF THE PHILIPPINES, HEIRS OF CASIANO DE LEON
and MARIA SOCORRO DE LEON, Respondents. |
G.R.
No. 151424
Present: YNARES-SANTIAGO, J., Chairperson, CARPIO MORALES,* CHICO-NAZARIO, NACHURA, and DE CASTRO,**JJ. Promulgated: July 31,
2009 |
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RESOLUTION
NACHURA, J.:
Petitioner Eagle Realty Corporation
seeks the reconsideration of this Court’s Decision dated July 4, 2008, which
affirmed the Court of Appeals Decision dated January 22, 2001 and Resolution
dated January 8, 2002, and upheld the cancellation of petitioner’s certificate
of title based on a finding that it is not a purchaser in good faith and for
value.
In the assailed decision, the Court
held that “a corporation engaged in the buying and selling of real estate is
expected to exercise a higher standard of care and diligence in ascertaining
the status and condition of the property subject of its business transaction.”
Citing Sunshine Finance and Investment
Corporation v. Intermediate Appellate Court,[1] the
Court declared that, similar to investment and financing corporations, such
corporation “cannot simply rely on an examination of a
Petitioner’s Motion for
Reconsideration centers on the application of Sunshine Finance to the present case. Petitioner argues therein that the ruling in Sunshine Finance is a recent innovation, established long after the
subject property was transferred in petitioner’s name in 1984, hence, should
not be applied to the case. Prior jurisprudence that
protected banks, investment corporations and realty companies, without imposing
any additional burden of going beyond the face of the title, should be applied
instead. Petitioner points out that it purchased
the subject property in 1984, when prevailing jurisprudence did not, as yet,
impose upon realty companies the obligation to look beyond the certificate of
title for it to qualify as an innocent purchaser for value. To charge
petitioner with such additional obligation is to burden it with a then
non-existent obligation which thus violates its right to due process.[2]
In its Comment, the Office of the
Solicitor General (OSG) averred that the ruling in Sunshine Finance is not in the nature of a statute that cannot be
retroactively applied; it is jurisprudence that merely restates the definition
of an innocent purchaser for value.[3]
We agree with the OSG and,
consequently, deny the motion for reconsideration.
Judicial
interpretation of a statute constitutes part of the law as of the date it was
originally passed, since the Court’s construction merely establishes the
contemporaneous legislative intent that the interpreted law carried into
effect. Such judicial doctrine does not
amount to the passage of a new law, but consists merely of a construction or
interpretation of a pre-existing one,[4] as
is the situation in this case. The assailed decision merely defines an
“innocent purchaser for value” with respect to entities engaged in the real
estate business.
In Sunshine Finance, the Court required,
for the first time, investment and financing corporations to take the necessary
precautions to ascertain if there were any flaws in the certificate of title and
examine the condition of the property they were dealing with. Although the
property involved was mortgaged to and, subsequently, purchased by therein
petitioner several years before the said decision was promulgated, we note that
the rule was immediately applied to that case.
Our herein assailed
ruling expands the ruling in Sunshine
Finance to cover realty corporations, which, because of the nature of their
business, are, likewise, expected to exercise a higher standard of diligence in
ascertaining the status of the property, not merely rely on what appears on the
face of a certificate of title. In like
manner, our ruling should be applied to the present case; otherwise, it would be
reduced to “a mere academic exercise with the result that the doctrine laid
down would be no more than a dictum, and would deprive the holding in the case
of any force.” [5]
The other arguments advanced
by petitioner are a mere rehash of the arguments in its previous pleadings,
which had already been passed upon adequately by the Court in the assailed
decision.
IN LIGHT OF THE FOREGOING, the Motion for Reconsideration is DENIED WITH FINALITY for lack of merit.
SO ORDERED.
ANTONIO
EDUARDO B. NACHURA
Associate
Justice
WE CONCUR:
CONSUELO YNARES-SANTIAGO
Associate
Justice
Chairperson
CONCHITA CARPIO MORALES Associate
Justice |
MINITA V. CHICO-NAZARIO Associate
Justice |
TERESITA J. LEONARDO DE CASTRO
Associate
Justice
A
T T E S T A T I O N
I attest that the conclusions in the above Resolution were
reached in consultation before the case was assigned to the writer of the
opinion of the Court’s Special Third Division.
CONSUELO
YNARES-SANTIAGO
Associate
Justice
Chairperson,
Third Division
C E R T I F I C A T I O N
Pursuant to Section 13, Article VIII of the Constitution
and the Division Chairperson's Attestation, I certify that the conclusions in
the above Resolution had been reached in consultation before the case was
assigned to the writer of the opinion of the Court’s Special Third Division.
REYNATO
S. PUNO
Chief
Justice
* Designated member per raffle dated March 18, 2009.
** Designated additional member per Special Order No. 669 dated July 15, 2009.
[1] G.R. Nos. 74070-71, October 28, 1991, 203 SCRA 210.
[2] Rollo, pp. 1523-1525.
[3]
[4] Senarillos v. Hermosisima, 101 Phil. 561 (1956).
[5] Serrano v. National Labor Relations Commission, 387 Phil. 345, 357 (2000).