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Tag: Section 108

  • Title Disputes: When Correcting a Title Requires a Full Court Hearing

    The Supreme Court ruled that altering a land title to change the owner’s civil status from “married” to “single” requires a full adversarial court proceeding, not a summary correction. This is necessary when there are conflicting claims or disputes about the property’s ownership or the registered owner’s marital status. This decision protects the rights of all parties who may have an interest in the property and ensures that significant title changes are thoroughly vetted.

    From Married to Single: A Contentious Title Correction

    This case revolves around a petition filed by Marie Josephine Cordero Solano to correct her name and marital status on two Transfer Certificates of Title (TCTs) for properties in Alabang Hills, Muntinlupa. The TCTs originally stated her name as “Ma. Josephine S. Cabañez, married to Benjamin H. Cabañez.” She sought to change this to “Marie Josephine C. Solano, single,” claiming they were never legally married and that the properties were exclusively hers. Benjamin H. Cabañez, however, contested this, leading to a legal battle over whether a simple correction was sufficient or if a more comprehensive legal proceeding was required.

    The core of the dispute lies in the interpretation of Section 108 of Presidential Decree No. 1529 (PD 1529), also known as the Property Registration Decree. This law governs the amendment and alteration of certificates of title. Section 108 allows a registered owner to petition the court for corrections of errors or omissions in the title. However, the Supreme Court has consistently held that this provision applies only to non-controversial, minor corrections.

    Specifically, Section 108 of PD 1529 states:

    Section 108. Amendment, and alteration of certificates. No erasure, alteration, or amendment shall be made upon the registration book after the entry of a certificate of title or of a memorandum thereon and the attestation of the same be Register of Deeds, except by order of the proper Court of First Instance. A registered owner of other person having an interest in registered property, or, in proper cases, the Register of Deeds with the approval of the Commissioner of Land Registration, may apply by petition to the court upon the ground that the registered interests of any description, whether vested, contingent, expectant or inchoate appearing on the certificate, have terminated and ceased; or that new interest not appearing upon the certificate have arisen or been created; or that an omission or error was made in entering a certificate or any memorandum thereon, or, on any duplicate certificate; or that the same or any person on the certificate has been changed; or that the registered owner has married, or, if registered as married, that the marriage has been terminated and no right or interests of heirs or creditors will thereby be affected; or that a corporation which owned registered land and has been dissolved has not convened the same within three years after its dissolution; or upon any other reasonable ground; and the court may hear and determine the petition after notice to all parties in interest, and may order the entry or cancellation of a new certificate, the entry or cancellation of a memorandum upon a certificate, or grant any other relief upon such terms and conditions, requiring security or bond if necessary, as it may consider proper; Provided, however, That this section shall not be construed to give the court authority to reopen the judgment or decree of registration, and that nothing shall be done or ordered by the court which shall impair the title or other interest of a purchaser holding a certificate for value and in good faith, or his heirs and assigns, without his or their written consent. Where the owner’s duplicate certificate is not presented, a similar petition may be filed as provided in the preceding section.

    The Court emphasized that the instances for amendment or alteration under Section 108 should be “non-controversial in nature” and limited to issues “so patently insubstantial as not to be genuine issues.” In this case, the change in marital status was far from simple. Benjamin Cabañez disputed the claim that they were never married and asserted an interest in the properties. This disagreement transformed the issue into a contentious one, requiring a more thorough legal examination.

    Building on this principle, the Court referenced previous rulings that clarify the scope of Section 108. In Tangunan v. Republic of the Philippines, the Supreme Court stated that Section 108 relief is only granted when “there is unanimity among the parties, or there is no adverse claim or serious objection on the part of any party in interest.” This precedent highlights that when disputes arise, a summary proceeding is insufficient; instead, a regular action is necessary to address the controversial issues.

    The Court noted that a separate action filed by Benjamin Cabañez’s wife (Leandra D. Cabañez) against Marie Josephine Cordero Solano complicated matters further. In that case, the RTC of Makati City had previously found that Benjamin and Leandra were the lawful owners of the properties. Although Marie Josephine claimed an amicable settlement waived Leandra’s rights, Benjamin later claimed he was deceived into signing an Affidavit of Declaration Against Interest. These conflicting claims underscored the need for a comprehensive adversarial proceeding to determine the true ownership and marital status.

    Furthermore, the Supreme Court cited Martinez v. Evangelista, where a petitioner sought to change their civil status on a title from “married” to “single.” The Court in Martinez held that such changes are “substantial as well as controversial, which can only be established in an appropriate adversary proceeding.” This ruling reinforces the principle that significant status changes affecting property rights require a full trial to resolve conflicting claims.

    Moreover, the Court pointed out that a land registration case is a proceeding in rem, meaning “against the thing.” Jurisdiction in such cases requires “constructive seizure of the land through publication and service of notice.” The Court found that Marie Josephine failed to comply with these requirements. Therefore, the initial RTC decision lacked proper jurisdiction.

    This approach contrasts with the Court of Appeals’ reliance on Chan v. Court of Appeals, where notice to the Register of Deeds was deemed sufficient. The Supreme Court clarified that Chan applied only because the petitioner and the Register of Deeds were the only parties with an interest in the correction. In the present case, Benjamin Cabañez had a clear interest to protect, making the Chan precedent inapplicable.

    In essence, the Supreme Court’s decision emphasizes the importance of due process and the protection of property rights. It clarifies that while Section 108 of PD 1529 provides a mechanism for correcting minor errors in land titles, it cannot be used to resolve substantial disputes or alter property rights without a full adversarial proceeding. This ensures that all parties with a potential interest in the property have an opportunity to be heard and that the court can thoroughly examine all relevant evidence before making a decision.

    The implications of this decision are significant for property owners and those involved in title disputes. It reinforces the principle that changes to marital status on a title, especially when contested, require a higher level of scrutiny than a simple administrative correction. It also serves as a reminder of the importance of complying with publication and notice requirements in land registration cases to ensure that all interested parties are properly informed and have the opportunity to participate.

    FAQs

    What was the key issue in this case? The key issue was whether changing the marital status on a land title from “married” to “single” could be done through a simple correction under Section 108 of PD 1529 or required a full adversarial proceeding.
    What is Section 108 of PD 1529? Section 108 of Presidential Decree No. 1529, the Property Registration Decree, allows for the amendment and alteration of certificates of title for minor, non-controversial errors or omissions.
    Why did the Supreme Court rule against the title correction in this case? The Supreme Court ruled against the title correction because there was a dispute over the marital status of the owner and a claim of interest in the property by another party, making it a controversial issue requiring a full trial.
    What is an adversarial proceeding? An adversarial proceeding is a legal process where opposing parties present their evidence and arguments in court, allowing a judge or jury to make a decision based on the facts and the law.
    What does “in rem” mean in the context of land registration? “In rem” means “against the thing,” indicating that a land registration case is a proceeding against the property itself, requiring proper notice to all potential claimants.
    What is the significance of publication and service of notice in land registration cases? Publication and service of notice are crucial because they ensure that all parties with a potential interest in the property are informed of the legal proceedings and have an opportunity to protect their rights.
    What happens if publication and service of notice are not properly followed? If publication and service of notice are not properly followed, the court may lack jurisdiction over the case, and any resulting decision could be deemed invalid.
    What type of cases are appropriate for Section 108 of PD 1529? Cases appropriate for Section 108 are those involving minor, non-controversial corrections of clerical errors or omissions in a land title, where there are no disputes about ownership or other interests in the property.
    What was the ruling in Martinez v. Evangelista and how does it apply to this case? In Martinez v. Evangelista, the Supreme Court held that changes in civil status on a title are substantial and controversial, requiring a full adversarial proceeding. This ruling was used to support the decision that changing marital status on the title in this case also required a full trial.

    This case underscores the importance of understanding the limitations of summary proceedings for title corrections and the necessity of a full adversarial process when disputes arise. Ensuring due process and protecting the rights of all interested parties are paramount in land registration matters.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Cabañez vs. Cabañez, G.R. No. 200180, June 6, 2016

  • Navigating Land Title Disputes: The Finality of Court Decisions and Limits of Summary Proceedings

    The Supreme Court’s decision in Philippine Veterans Bank v. Ramon Valenzuela underscores the principle of the immutability of final judgments and the limitations of summary proceedings under Section 108 of Presidential Decree (PD) No. 1529, also known as the Property Registration Decree. The Court held that a final and executory judgment, even if perceived as erroneous, can no longer be modified. Furthermore, the Court clarified that Section 108 of PD No. 1529, which allows for amendments or alterations of certificates of title, is only applicable to non-contentious issues. This ruling highlights the importance of diligently pursuing legal remedies within the prescribed periods and understanding the scope of allowable actions in land registration cases, safeguarding the stability and reliability of land titles.

    When a Bank’s Bid to Correct a Title Entry Collides with a Final Court Ruling

    The case revolves around Philippine Veterans Bank (PVB) seeking to correct an entry in a Transfer Certificate of Title (TCT) concerning a property it acquired through foreclosure. PVB claimed that Entry No. 9242 on TCT No. T-105375 erroneously reflected the details of another certificate of sale, instead of the one issued to PVB for P1,923,878.40. Ramon Valenzuela, one of the heirs of the registered owners, opposed the petition, arguing that the certificate of sale was never duly registered and that the issue was already being litigated in a separate civil case. The Regional Trial Court (RTC) initially granted PVB’s petition but later reversed its decision, relying on a Court of Appeals (CA) resolution stating that the certificate of sale was not registered. This led to the Supreme Court (SC) deciding whether the RTC erred in relying on the CA’s resolution to dismiss PVB’s petition.

    The Supreme Court emphasized the well-established principle of res judicata, which dictates that a final judgment is conclusive between the parties and their successors in interest, preventing the relitigation of the same issues. The Court cited National Tobacco Administration v. Castillo, stating that judgments that have become final and executory are immutable and unalterable, even if the perceived error is one of fact or law. The finality of the CA resolution finding that the Certificate of Sale involving TCT No. T-105375 was not registered with the Register of Deeds of Bulacan, became a binding fact. This factual finding could no longer be disputed by PVB, as the issue had already been conclusively determined in a prior proceeding.

    The Court further explained the scope and limitations of Section 108 of PD No. 1529, the legal basis for PVB’s petition. This section allows a person with an interest in registered property to petition the court for amendments or alterations to a certificate of title under certain circumstances. However, the Court emphasized that proceedings under Section 108 are summary in nature and are only appropriate for resolving non-controversial issues or clerical errors. As the Court stated:

    While the abovequoted section, among other things, authorizes a person in interest to ask the court for any erasure, alteration, or amendment of a certificate of title or of any memorandum appearing therein, the prevailing rule is that proceedings thereunder are summary in nature, contemplating corrections or insertions of mistakes which are only clerical but certainly not controversial issues.

    The presence of a serious objection and adverse claim from Valenzuela, coupled with the ongoing civil case (Civil Case No. 414-M-97) challenging PVB’s title, indicated a clear lack of unanimity among the parties. This made the summary proceedings under Section 108 inappropriate. The RTC’s decision in Civil Case No. 414-M-97, which ordered the cancellation of PVB’s TCT due to the non-registration of the Certificate of Sale, further highlighted the contentious nature of the issue.

    The Court also pointed out that PVB’s recourse was not to seek a correction of entry but to register the Certificate of Sale, which it had not yet done. The Court noted that there was no legal impediment preventing PVB from registering the Certificate of Sale with the Register of Deeds of Bulacan. Thus, PVB’s petition was denied, and the RTC’s order dismissing the petition for correction of entry was affirmed.

    This case serves as a reminder of the importance of understanding the nature of legal proceedings and choosing the appropriate remedy. The summary nature of proceedings under Section 108 of PD No. 1529 is not designed to resolve complex or contentious issues involving adverse claims or conflicting interests. When such issues arise, the proper course of action is to pursue an ordinary civil action where all parties can present their evidence and arguments in a full and fair hearing.

    Moreover, this case underscores the significance of registering documents affecting land titles promptly and accurately. The failure to register a certificate of sale can have significant consequences, including delaying the commencement of the redemption period and potentially jeopardizing the rights of the purchaser. Parties involved in real estate transactions must ensure that all necessary documents are properly registered to protect their interests and avoid future disputes.

    The decision also reinforces the principle of immutability of judgments, a cornerstone of the judicial system. Once a judgment becomes final and executory, it can no longer be altered, even if it is based on an erroneous interpretation of facts or law. This principle promotes stability and finality in legal proceedings, preventing endless litigation and ensuring that parties can rely on court decisions with certainty.

    FAQs

    What was the key issue in this case? The key issue was whether the RTC erred in relying on a Court of Appeals resolution to dismiss Philippine Veterans Bank’s petition for correction of entry in a Transfer Certificate of Title. The CA resolution stated the Certificate of Sale involving the land was not registered.
    What is Section 108 of PD No. 1529? Section 108 of PD No. 1529, also known as the Property Registration Decree, allows a person with an interest in registered property to petition the court for amendments or alterations to a certificate of title. However, it’s applicable only to non-controversial issues or clerical errors.
    What does res judicata mean? Res judicata is a legal doctrine that prevents the relitigation of issues that have already been decided in a final judgment. It ensures that a final judgment is conclusive between the parties and their successors in interest.
    Why was PVB’s petition denied? PVB’s petition was denied because the issue of non-registration of the Certificate of Sale was already settled in a prior CA resolution, which had become final. Also, there was an existing dispute and adverse claim, making a summary proceeding inappropriate.
    What type of proceeding is under Section 108 of PD No. 1529? The proceedings under Section 108 of PD No. 1529 are summary in nature, meaning they are designed for quick resolution of non-controversial issues or clerical errors. They are not appropriate for resolving complex disputes involving adverse claims.
    What was the proper recourse for PVB? The Court stated that PVB’s proper recourse was to register the Certificate of Sale with the Register of Deeds of Bulacan. The court noted that nothing was preventing PVB from doing so.
    What is the principle of immutability of judgments? The principle of immutability of judgments states that once a judgment becomes final and executory, it can no longer be altered, even if it is based on an erroneous interpretation of facts or law. This promotes stability and finality in legal proceedings.
    What happens when there is an adverse claim during a petition for correction of entry? When there is an adverse claim or serious objection, the summary proceedings under Section 108 are no longer appropriate. The parties must pursue an ordinary civil action where all parties can present their evidence and arguments in a full hearing.

    In conclusion, Philippine Veterans Bank v. Ramon Valenzuela reinforces the importance of adhering to the principles of finality of judgments and understanding the limitations of summary proceedings in land registration cases. Parties must be diligent in pursuing their legal remedies and ensuring that all necessary documents are properly registered to protect their rights and interests.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Philippine Veterans Bank v. Valenzuela, G.R. No. 163530, March 09, 2011

  • Navigating Land Title Disputes: Why Summary Petitions Fall Short in Ownership Battles – Quevada v. Glorioso

    When Summary Land Registration Petitions Fail: Understanding the Limits of Section 108/112 in Philippine Property Law

    In Philippine property law, correcting errors or making annotations on land titles sometimes requires court intervention. However, not all title issues can be resolved through a simple, expedited process. The Supreme Court case of Quevada v. Glorioso clearly illustrates that summary petitions under Section 108 (now Section 103 of PD 1529) of the Land Registration Act are insufficient when the core issue is a dispute over land ownership itself. This case serves as a crucial reminder that while summary petitions offer a streamlined approach for minor title adjustments, they are not a substitute for full-blown legal actions when ownership is genuinely contested.

    G.R. No. 121270, August 27, 1998

    INTRODUCTION

    Imagine inheriting land that your family has considered theirs for generations, only to discover that a portion is claimed by distant relatives based on a decades-old, seemingly simple court order. This scenario isn’t uncommon in the Philippines, where land disputes often entangle families and span generations. The case of Quevada v. Glorioso revolves around just such a family feud over a piece of land in Sariaya, Quezon. At the heart of the dispute lies a critical question: Can a summary petition for inscription under Section 108 of the Land Registration Act effectively resolve a fundamental disagreement about who rightfully owns a portion of registered land? This case delves into the limitations of summary land registration proceedings and underscores the necessity of proper legal action to settle ownership disputes.

    LEGAL CONTEXT: SECTION 108 AND SUMMARY PETITIONS

    To understand the crux of Quevada v. Glorioso, it’s essential to grasp the concept of summary petitions under Section 108 (now Section 103 of Presidential Decree No. 1529, also known as the Property Registration Decree) of the Land Registration Act. This legal provision offers a simplified court procedure for specific, non-contentious alterations or annotations on existing land titles. Section 108 states:

    “Sec. 108. Amendment and alteration of certificates. No erasure, alteration, or amendment shall be made upon the registration book after the entry of a certificate of title or of a memorandum thereon and the attestation of the same by the clerk or any register of deeds, except by order of the court…“

    This section allows registered owners or interested parties to petition the court for corrections of errors, omissions, or mistakes in certificates of title, or to annotate new interests or terminated interests. Crucially, these proceedings are meant to be summary, meaning they are expedited and less formal than ordinary civil actions. They are designed for straightforward, non-adversarial situations where there is no substantial dispute among the parties.

    However, the Supreme Court has consistently emphasized that Section 108 proceedings are not intended for resolving complex issues, particularly those involving disputed ownership. These summary proceedings are inappropriate when there’s a genuine controversy or adverse claim to the property. As jurisprudence dictates, Section 108 is meant for “non-controversial” matters, limited to “issues so patently insubstantial as not to be genuine issues.” When ownership itself is the core issue, a plenary action, such as an action for reconveyance or quieting of title, is the proper legal avenue, ensuring due process and a thorough examination of evidence.

    CASE BREAKDOWN: QUEVADA V. GLORIOSO

    The roots of the Quevada v. Glorioso dispute stretch back to 1923 when Antonio Cerrudo acquired land during his marriage to Pomposa Glorioso and registered it under the Torrens System. Antonio passed away, leaving his wife Pomposa and son Pablo as heirs. In 1925, the land title (OCT No. 8204) was issued solely in Antonio’s name.

    Fast forward to 1934, Pablo, Antonio’s son, purportedly executed a document ceding half of the property to his aunt, Gregoria Cerrudo, Antonio’s sister. This document, while signed by Pablo, his mother Pomposa, and Gregoria, wasn’t formally registered on the title. Years later, in 1948, Gregoria filed a “Petition for Inscription” in court, seeking to annotate her claimed half-ownership based on Pablo’s document. Notably, this petition was filed under Section 108, a summary proceeding.

    Adding to the complexity, Pablo’s widow, Roberta Nañez, and mother, Pomposa Glorioso, executed a “Joint Affidavit” supporting Gregoria’s petition. The Court of First Instance (CFI) granted the petition in a resolution dated June 5, 1948, and the Register of Deeds inscribed annotations on OCT No. 8204 reflecting Gregoria’s claim to half the land.

    Decades later, in 1978, Gregoria sold her claimed portion to her children, the Quevadas. When the Quevadas attempted to subdivide the property based on the inscription, the Cerrudos – Pablo’s children – objected. This led to the Cerrudos filing a case in 1979 to nullify the 1948 CFI order, the inscriptions, and the sale to the Quevadas.

    The Regional Trial Court (RTC) ruled in favor of the Cerrudos, declaring the 1948 CFI order void for lack of jurisdiction, as Section 108 was improperly used to settle an ownership dispute. The Deed of Sale was also invalidated. The Court of Appeals (CA) affirmed the RTC’s decision, emphasizing the impropriety of using a summary petition to resolve a contested ownership claim. The appellate court stated that the “petition for inscription” was an improper remedy, and an action for reconveyance would have been more appropriate, though it had already prescribed.

    The Supreme Court, in its decision, upheld the lower courts. Justice Kapunan, writing for the Court, stated:

    “Clearly, Gregoria’s claim of ownership could not have been settled by filing a mere ‘petition for inscription’ which is actually a proceeding under Section 112 of the Land Registration Act. Said section reads… The proceedings under the aforequoted section are inadequate to settle the issue of ownership over the disputed portion. Matters described in Section 112 are non-controversial in nature. They are limited to issues so patently insubstantial as not to be genuine issues. These proceedings are summary in nature, contemplating insertions of mistakes which are only clerical, but certainly not controversial issues.“

    The Supreme Court highlighted that Gregoria’s petition was based on a claim of co-ownership due to inheritance, a contentious issue unsuitable for summary proceedings. Furthermore, the Court noted the lack of representation for Pablo’s children (the Cerrudos) in the 1948 proceedings, further undermining the validity of the CFI order.

    The Court rejected the Quevadas’ arguments of prescription and laches, finding that the Cerrudos’ action was not barred. The Court also affirmed the order for the Quevadas to vacate the property and pay rent, as their possession became unlawful when the Cerrudos contested their claim.

    PRACTICAL IMPLICATIONS: WHEN TO USE SECTION 108 AND WHEN NOT TO

    Quevada v. Glorioso provides crucial guidance for property owners and legal practitioners regarding the appropriate use of Section 108 (now Section 103 of PD 1529). The case firmly establishes that summary petitions are limited to non-contentious matters. They are suitable for:

    • Correcting minor clerical errors on a title (e.g., misspelled names, typographical errors in descriptions).
    • Annotating or cancelling mortgages, liens, or other encumbrances when all parties agree.
    • Reflecting changes in marital status of the registered owner.
    • Registering consolidations or subdivisions of land when there are no ownership disputes.

    However, Section 108 proceedings are inappropriate when:

    • There is a genuine dispute about land ownership.
    • Adverse claims or conflicting interests in the property exist.
    • The relief sought goes beyond mere clerical correction and affects substantive rights.
    • Due process requires a full trial to present and examine evidence (e.g., issues of fraud, misrepresentation, or validity of documents).

    In cases involving ownership disputes, parties must resort to plenary actions like:

    • Action for Reconveyance: To compel the transfer of property to the rightful owner when it was erroneously registered in another’s name.
    • Action to Quiet Title: To remove clouds or doubts over the title to real property.
    • Ejectment Suit: To recover possession of property from an unlawful possessor.
    • Partition Suit: To divide co-owned property among the owners.

    Key Lessons from Quevada v. Glorioso:

    1. Summary Petitions are for Minor Corrections, Not Ownership Battles: Section 108/112 is designed for administrative corrections, not for resolving fundamental disputes about who owns the land.
    2. Due Process is Paramount: When ownership is contested, all parties with potential claims must be properly notified and given a chance to present their case in a full trial. Summary proceedings often lack this due process for complex disputes.
    3. Seek Proper Legal Action: Attempting to resolve ownership disputes through summary petitions can be ineffective and lead to prolonged legal battles. Consult with a lawyer to determine the correct legal action based on the specific facts of your case.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q1: What is Section 108 (now 103 of PD 1529) of the Land Registration Act/Property Registration Decree?

    A: It’s a provision in Philippine law that allows for summary court proceedings to correct minor errors, omissions, or make annotations on land titles without needing a full-blown trial. It’s intended for non-controversial matters.

    Q2: When can I use a Section 108/103 petition?

    A: You can use it for simple corrections like misspelled names, typographical errors, annotating agreed-upon encumbrances, or reflecting changes in marital status, as long as there are no disputes about ownership or substantive rights.

    Q3: When should I NOT use a Section 108/103 petition?

    A: Do not use it if there’s a dispute about who owns the land, if there are adverse claims, or if you need to resolve complex legal issues requiring a full trial and presentation of evidence.

    Q4: What happens if I incorrectly use a Section 108/103 petition for an ownership dispute?

    A: The court order issued in a summary proceeding may be declared void for lack of jurisdiction, as seen in Quevada v. Glorioso. You might have to start over with a proper plenary action, wasting time and resources.

    Q5: What are the proper legal actions for resolving land ownership disputes?

    A: Proper actions include Actions for Reconveyance, Actions to Quiet Title, Ejectment Suits, and Partition Suits. These require a full trial and are designed to address complex ownership issues.

    Q6: Is there a time limit to question an improper Section 108/103 order?

    A: The usual rules of prescription and laches may apply, but as Quevada v. Glorioso shows, laches may not bar an action if possession was merely tolerated and the fundamental issue of jurisdiction is raised.

    Q7: What is a plenary action in land registration cases?

    A: A plenary action is a regular court proceeding, unlike a summary petition. It involves full hearings, presentation of evidence, and is appropriate for resolving complex or contested issues, especially those concerning land ownership.

    Q8: How can I ensure my land title is properly corrected or annotated?

    A: Consult with a qualified lawyer specializing in property law. They can assess your situation and advise you on the correct legal procedure, whether it’s a summary petition or a plenary action.

    ASG Law specializes in Property Law and Litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.