28/01/2026
The 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session today, January 28, 2026, denied the petition filed by the Republic of the Philippines, through the Office of the Solicitor General, which questioned the removal of an annotation on respondent Antonio V. Mitra’s (Mitra) land title.
Mitra owns a parcel of land in Quezon City. After his transfer certificate of title (TCT) was presumed lost or destroyed, he applied for administrative reconstitution.
Following Republic Act (R.A.) No. 26, the law that governs the reconstitution of lost or destroyed titles, the reconstituted title contained an annotation stating that it was without prejudice to any party whose right or interest in the property was duly noted on the original copy at the time it was lost or destroyed.
Twenty-seven years later, Mitra asked the Regional Trial Court (RTC) to cancel the annotation, pointing out that no one had claimed any interest in the property during that period. The RTC granted the request and ordered the removal of the annotation. The Court of Appeals upheld the RTC, ruling that the publication and posting requirement no longer applied because of the long lapse of time since the title was reconstituted.
Agreeing with the Court of Appeals, the SC explained that under R.A. No. 26, posting and publication are required only if the petition to cancel the mandatory annotation is filed within two years from the date of administrative reconstitution, and no petition to annotate an omitted interest has been filed during that period.
Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=159902.
The full text of the Decision in G.R. No. 264862, Republic of the Philippines v. Antonio V. Mitra, shall be uploaded to the Supreme Court website once available.
