Facts:

The case involves Enrique Altavas, the Chief of the General Land Registration Office, as the petitioner, and P. M. Mom, the Judge of the Court of First Instance of the Seventh Judicial District, as the respondent. The events leading up to the case began with a registration proceeding initiated by the Roman Catholic Apostolic Church to register certain parcels of land. The court issued a judgment that ultimately decreed the registration of the title as requested. On September 30, 1915, the court issued an order directing Altavas to comply with Section 21 of Act No. 2347, which mandated that a certified copy of the final court decision be sent to the Chief of the General Land Registration Office so that decrees could be prepared and forwarded to the relevant registrar.

On February 28, 1916, Altavas reported to the court that the necessary decrees had not been issued because the surveyors were still examining the plans due to the high volume of parcels involved. He also noted the

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Facts:

Background of the Land Registration Proceedings

• The original proceeding was instituted in the Court of Land Registration by the Roman Catholic Apostolic Church to register title to certain parcels of land.
• A final judgment was rendered, decreeing the registration of the title substantially as prayed.

The Court’s Order and Statutory Mandate

• On September 30, 1915, the Court of Land Registration, upon motion of the applicant, issued an order directing the Chief of the General Land Registration Office (GLRO) to comply with section 21 of Act No. 2347.
• Section 21 of Act No. 2347 required that immediately after the final decision, the clerk send a certified copy of the decision to the Chief, who would then prepare and forward a decree for registration as stipulated by the subsequent provisions of Act No. 496.

The Chief’s Return and the Issue of Additional Fees

• On February 28, 1916, the Chief of the General Land Registration Office submitted a return stating that the decrees had not yet been issued because the surveyors had not completed the necessary examination of plans and technical descriptions due to the large number of parcels involved.
• The Chief cited the recent passage of Act No. 2556, contending that under its provisions (specifically section 3), additional fees needed to be paid by the applicant before the decrees could be issued.
• Attached to the return were two exhibits:
• Exhibit A – A copy of a communication dated February 15, 1916, addressed to the applicant.
• Exhibit B – A certificate detailing the amount due by the applicant pursuant to Act No. 2556.
• The Chief recommended that the Court take steps to require the applicant to make the additional payment and to suspend the order for issuance of the decrees until the fees were paid.

The Court’s Rejection of the Chief’s Suggestion

• On March 3, 1916, the Court issued a second order.
• The Court rejected the suggestion made by the Chief in his return and reiterated the directive to comply with the provisions of section 21 of Act No. 2347 without imposing the additional fees mandated by Act No. 2556.
• The Court warned that noncompliance would result in punishment for contempt.

Filing of the Bill of Exceptions and the Mandamus Action

• On July 19, 1916, the Chief presented a bill of exceptions to the Court for approval, aiming to prosecute it based on the March 3, 1916, order.
• The Court refused to approve the bill on the grounds that the Chief was not a party to the original proceedings in the Court of Land Registration.
• As a result, the Chief (petitioner's office) brought a mandamus action to compel the Court to approve the bill of exceptions.

Recast Issues on Fee Imposition

• While the central issue appeared to be the approval of the bill, both parties ultimately reframed the question to address whether the Roman Catholic Apostolic Church should be required to pay the additional fees under Act No. 2556 or continue with the fees prescribed by the law in effect prior to the passage of said Act.
• It was emphasized that the Church had obtained a final decree registering title before the enactment of Act No. 2556, thus asserting its right to have the evidences of title issued based on the earlier statutory provisions.

Issue:

Standing of the Chief of the GLRO

• Whether the Chief, not being a party to the original Land Registration proceedings, had the legal standing to file and prosecute a bill of exceptions.

Validity of the Court’s Directive Under Competing Statutory Provisions

• Whether the Court’s order directing the Chief to comply with section 21 of Act No. 2347 was properly issued despite the Chief’s assertion of additional fee requirements under the newly enacted Act No. 2556.

Determination of Applicable Fee Regime

• Whether the fees payable by the petitioner (as represented by the Roman Catholic Apostolic Church) should be computed under the statute in force prior to the passage of Act No. 2556, given that the final judgment was rendered before the enactment of the new fee requirements.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)