Facts:

This case, Manuela Grey Alba et al. vs. Anacleto R. de la Cruz, was resolved by the Supreme Court of the Philippines on September 16, 1910 (G.R. No. 5246). The petitioners, Manuela, Jose, Juan, and Francisco Grey y Alba, are heirs of the deceased Dona Segunda Alba Clemente and Honorato Grey. They filed a petition on December 18, 1906, to register a parcel of agricultural land located in Talampas, Baliuag, Bulacan, with an area of approximately 52 hectares and various improvements. The property, assessed at $1,000, was reportedly used for rice and sugar cane cultivation.

A decree solicited by the petitioners was granted on February 12, 1908, admitting them as co-owners but recognizing the usufructuary right of Vicente Reyes, the widower of their deceased sister, Remedios Grey y Alba. Subsequently, on June 16, 1908, Anacleto R. de la Cruz filed a motion to reconsider this decree, claiming ownership over two parcels included in the land specified in the petition, asserting that he

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Facts:

Parties and Inheritance

• The petitioners – Manuela, Jose, Juan, and Francisco Grey Alba – are the sole heirs of Dona Segunda Alba Clemente and Honorato Grey.
• Remedios Grey Alba, a sister of the petitioners, married Vicente Reyes on March 21, 1903, and died on July 13, 1905, leaving only her husband as an heir.
• The petitioners inherited a parcel of agricultural land from their parents, which included the two small parcels at issue.

Description of the Property and Registration Petition

• The property is a parcel of land situated in the barrio of Talampas, municipality of Baliuag, Province of Bulacan, described as having three houses and one camarin made of light material over an area of 52 hectares, 51 ares, and 22 centares.
• It is bounded by identifiable landmarks and neighboring properties, and it is primarily used for the cultivation of rice and sugar cane.
• The petitioners filed their application on December 18, 1906, accompanied by a technical description and plan, seeking registration of the entire property in their names as co-owners, with a stipulated usufructuary right in favor of Vicente Reyes, the widower of Remedios Grey.

Entry of the Decree and Subsequent Developments

• On February 12, 1908, the court issued a decree, in accordance with paragraph 6 of section 54 of Act No. 926, directing the registration of the property in the petitioners’ names as co-owners, subject to the usufruct of Vicente Reyes.
• On June 16, 1908, Anacleto R. de la Cruz (objector/appellee) filed a motion for revision under section 38 of the Land Registration Act (Act No. 496), alleging that:
• He is the absolute owner of two small parcels included in the property description by virtue of a state grant acquired in March 1895 from his father, Baldomero R. de la Cruz.
• The decree of February 12, 1908, was obtained fraudulently by the petitioners, particularly through the omission of his name—although he was occupying the land.
• The Land Court reopened the case, and on November 23, 1908, issued a revised decision modifying the original decree by excluding the two parcels claimed by Anacleto.

Evidence and Transactional History

• The petitioners assert that the disputed two parcels were purchased by their parents in 1864, as evidenced by a public purchase document executed before the alcalde mayor and a judge.
• Contrastingly, the appellee’s father obtained a state grant in 1895 covering several parcels, including the disputed ones, which was subsequently inscribed in the register by April of the same year.
• Rental contracts further complicate the factual background:
• In 1882, the petitioners’ uncle (Jose Grey) rented the land to Irineo Jose for three years.
• On March 23, 1895, Jose Grey rented the same land for six years to Baldomero R. de la Cruz, during which the land was cultivated by him and his children, including the appellee.
• A later contract, dated December 14, 1905, between Jose Grey and Estanislao R. de la Cruz (brother of the appellee), reportedly included the two small parcels, though the appellee contends otherwise.

Omission of the Appellee’s Name and Alleged Fraud

• The petitioners did not list the appellee as an occupant in their petition, asserting that they believed he was occupying the property as a tenant rather than as an owner.
• The trial court held that this omission constituted a violation of section 21 of Act No. 496 and amounted to fraud—allegedly sufficient to warrant reopening the case.
• The contention rested on whether the omission and the subsequent modification of the decree (excluding the two disputed parcels) were justified under the provisions of the Land Registration Act.

Relevant Registration Procedure and Legal Notice Requirements

• Under the Land Registration Act (Act No. 496), an application must:
• Be in writing, properly signed, and accompanied by an accurate description of the land.
• Include the names and addresses of the applicant, all occupants, adjoining owners, and any persons who might have an interest in the property.
• Be subject to a notice procedure that involves publication in the Official Gazette and posting on the property and municipal building, ensuring the right to be heard for all notified parties.
• The decree of February 12, 1908, was entered after these formalities, and its conclusive effect is emphasized, except in cases of fraud as defined by the statute.

Issue:

• Whether the trial court erred in reopening the registration case in June 1908 after having already issued a decree on February 12, 1908, particularly when the alleged omission of the appellee’s name did not stem from actual fraud.
• Whether the petitioners’ failure to include the appellee as an occupant in their original petition constitutes actionable fraud under section 38 of Act No. 496.
• Whether the dispute over the two small parcels should be resolved in favor of the appellee’s claim (based on the state grant and rental contract interpretations) or the petitioners’ title (based on the public document of purchase from 1864).
• Whether the procedures followed in the registration process, including the general notice “to all whom it may concern,” satisfy the requirements of due process under both the Land Registration Act and the Philippine Bill of Rights (particularly section 5 of the Philippine Bill).
• Whether the principles underlying the Torrens system, which confer indefeasibility upon registered titles, preclude reopening the decree on a basis of constructive or alleged fraud when no positive fraudulent intent is demonstrated.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)