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PEDRO CRISOLO v. HIGINO B. MACADAEG

This case has been cited 3 times or more.

2009-06-23
QUISUMBING, J.
True, a duly-registered certificate of title is considered a public document and the entries found in it are presumed correct, unless the party who contests its accuracy can produce evidence establishing otherwise.[36] Even then, records of public officers which are admissible in evidence are limited to those matters which the public officer has authority to record.[37] Indisputably, it was beyond the power of the Register of Deeds to register a public land based on an invalid, much worse, a non-existent patent. To sanction an otherwise invalid document in the guise of upholding the stability of our land registration system would run counter to the judicial devotion towards purging the system of illicit titles, in accordance with our base task as the ultimate citadel of justice and legitimacy.[38]
2002-02-06
BELLOSILLO, J.
What follows is the pathetic story of private respondent Eusebia R. Galzote as recorded by the Civil Service Commission, adopted and sustained by the Court of Appeals:  Private respondent was employed as a clerk in the Department of Engineering and Public Works of Makati City.[4] On 6 September 1991 she was arrested without warrant and detained allegedly for kidnapping for ransom with physical injuries, and thereafter subjected to inquest proceedings[5] with the criminal case eventually docketed as Crim. Case No. 88357 of the Regional Trial Court of Pasig, Metro Manila.[6] Incarcerated from then on, she could not report for work as a result of which she was suspended from office by petitioner City Government starting 9 September 1991 until the final disposition of her case.[7] Unfortunately, however, the City Government thereafter changed its policy.  Without informing private respondent who was then already detained at the Rizal Provincial Jail,[8] and even as her trial for the criminal case was going on, she was dropped from the rolls of municipal employees effective 21 January 1993 for having been absent from work for more than one (1) year without official leave.[9]