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278514 Sotero Diola, Felixberto Cubero, Judy U. Lim, Manuel R. Lahoz, and Nerissa C. Natividad Vs. Laguna West Multi-Purpose Cooperative, Inc. — Official PDF
278514 — Promulgated July 7, 2026 · 2026 · Supreme Court 2026 / Decision or signed resolution
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DIGITAL P. 3 / 7
Decision 3 G.R. No. 278514
they contended that the mandamus petition was filed out of time. Since there
was no order explicitly denying Laguna West's demand, the 60-day
reglementary period should be reckoned from the expiration of 15 days from
the time it was received by the Register of Deeds. Second, they argued that
Laguna West failed to exhaust administrative remedies, having neither moved
for reconsideration nor elevated the matter en consulta to the Land
Registration Authority. Lastly, they maintained that the JVAs were void for
violating the proscription against the transfer of lands conferred through
certificates of land ownership award. 13
Ruling of the RTC
The RTC conducted a hearing on the affirmative defenses raised by
Diola et al. and thereafter issued an Order denying the same. This ruling was
later affirmed by the CA via the action for certiorari filed by Diola et al. in
CA-G.R. SP No. 150402. 14 In due course, the RTC rendered the Decision
granting the Amended Petition for Mandamus and disposing as follows:
WHEREFORE, premises considered, the petition is GRANTED.
Let a Writ of [Mandamus] be issued directing the respondent Register of
Deeds of Tanauan City, Batangas, to carry over and annotate the adverse
claims of [Laguna West], appearing in [the] following cancelled titles with
their respective adverse claim entry numbers, to their respective succeeding
titles.
SO ORDERED. 15 (Emphasis in the original)
In its Decision, the RTC brushed aside the issue regarding the validity
of the subject JVAs, stating that jurisdiction on the administrative
implementation of agrarian laws exclusively pertains to the Department of
Agrarian Reform Adjudication Board. 16 As regards the procedural
requirements of the petition for mandamus, the RTC ruled that these had
already been raised as affirmative defenses and were accordingly denied. It
nonetheless reiterated that, because the Register of Deeds' inaction was the
very premise of Laguna West's mandamus petition, there was no judgment,
order, or resolution from which notice could be reckoned. 17 On the substantive
aspect, the RTC held that the Register of Deeds' failure to perform its
ministerial duty to carry over the omitted adverse claim was an omission
compellable by mandamus. 18
13 Id. at 37-38.
14 id. at 15, 38-39.
15 id. at 308.
16 Id. at 305.
17 Id. at 306.
18 /d.at307.
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