Facts:

In the case of Albino Nicolas, et al. vs. The Director of Lands, Guillermo Camungao (G.R. Nos. L-19147-8), decided on December 28, 1963, the proceedings arose from applications for land registration under the Torrens System. Albino Nicolas filed his application for Lots 1 and 2 (PSU-128816) on October 20, 1951. Shortly thereafter, Eusebio Coloma also sought registration for the same lots (PSU-129626) on December 19, 1951. Prior to any hearings, Guillermo Camungao filed a written opposition, claiming ownership of Lot 2 from his Sales Application No. 2091 (E-3989). Despite his opposition, the Provincial Fiscal, representing the Director of Lands, similarly opposed the registration, arguing the two lots were public lands covered by Camungao's Sales Application.

On August 22, 1952, the lower court declared a General Default against both applications, excluding the Director of Lands. A hearing was later conducted without notifying Camungao, who was unaware of the proceedings and

Facts:

• Application for Registration: On October 20, 1951, Albino Nicolas filed an application to register Lots 1 and 2, PSU-128816, under the Torrens System. On December 19, 1951, Eusebio Coloma also applied for the registration of Lots 1 and 2, PSU-129626.

• Opposition by Guillermo Camungao: Before the initial hearings, Guillermo Camungao filed a written appearance opposing the registration of Lot 2 in both PSUs, claiming ownership based on Sales Application No. 2091 (E-3989), which had been awarded to him.

• Opposition by the Director of Lands: The Provincial Fiscal, representing the Director of Lands, opposed the applications, asserting that Lot 2 in both PSUs were public lands covered by the same Sales Application No. 2091 (E-3989).

• Order of General Default: On August 22, 1952, the lower court issued an Order of General Default in both cases, except as to the Director of Lands. Notice of the hearing was sent only to the Provincial Fiscal, not to Camungao.

• Judgment and Decree of Registration: On September 30, 1955, the court adjudicated the lands in favor of Nicolas and Coloma. The judgment became final, and a decree of registration was issued.

• Eviction and Petition for Review: On January 21, 1956, an eviction order was issued against Camungao, who then filed a petition on April 25, 1956, to set aside the court’s decision, alleging fraud, lack of notice, and continuous possession since 1936.

• Motion to Dismiss: On May 16, 1956, the respondents moved to dismiss Camungao’s petition, arguing no cause of action and that actual fraud was required for review.

• Lower Court’s Dismissal: On December 12, 1956, the lower court dismissed Camungao’s petition, stating that his opposition was invalid as it was unsworn and that he was represented by the Director of Lands during the hearing.

Issue:

1. Whether the lower court erred in dismissing Camungao’s petition for lack of cause of action.

2. Whether the lack of notice to Camungao and the alleged fraudulent acts by the respondents constitute grounds for setting aside the registration judgment.

3. Whether the written appearance and opposition filed by Camungao were sufficient to entitle him to notice and standing in court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)