Facts:

• Albino Nicolas and Eusebio Coloma filed applications to register Lots 1 and 2 under the Torrens System on October 20, 1951, and December 19, 1951, respectively.
• Guillermo Camungao opposed the registration, claiming ownership of Lot 2 through Sales Application No. 2091 (E-3989).
• The Director of Lands, represented by the Provincial Fiscal, also opposed the applications, asserting that the lots were public lands covered by Camungao's sales application.
• On August 22, 1952, the lower court issued an Order of General Default, excluding the Director of Lands.
• A hearing was held without notifying Camungao, despite his opposition.
• On September 30, 1955, the court adjudicated the lands in favor of the applicants.
• Camungao learned of the decision only on January 21, 1956, when an eviction order was issued against him.
• He filed a petition on April 25, 1956, to set aside the decision, alleging fraud and lack of notice.
• The lower court dismissed his petition on December 12, 1956, stating that the fraud alleged was not actual fraud and that Camungao's opposition was not valid as it was not sworn to.
• The case was then brought to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court set aside the lower court's decision and remanded the case for proper proceedi...(Unlock)

Ratio:

• The Supreme Court found that the allegations in Camungao's petition described acts of actual fraud, such as the intentional omission of his possession of the lots and misleading the court about the contiguity of the properties.
• The court emphasized that actual fraud involves intentional deception to deprive another of their rights.
• The lower court erred in dismissing the petition without a formal hearing...continue reading