Facts:

The case of Constantino Alvarez, Jr., Casildita Alvarez de Muertegui, and Rosalia Alvarez Vda. de Tan v. Court of Appeals and Heirs of Segundo Garcia Fernandez (G.R. No. 60443) arose from a long-standing dispute over Lot No. 689, located in Ormoc City, Leyte. This cadastral proceeding began in April 1936 when the Director of Lands filed a petition for the settlement and adjudication of land titles, including Lot No. 689. Initially, no claims were made on this lot despite legal notices, leading to an order of general default and dismissal of the proceedings on April 1, 1942. A petition to lift this order was made in 1940 by the children of Segundo Garcia Fernandez, who were unsuccessful in their appeal due to technicalities.

In July 1956, Constantino Alvarez, Jr., along with his sisters, filed a motion to reopen the case and claim ownership of Lot No. 689 as the voluntary heirs of the spouses Segundo Garcia Fernandez and Eulogia Alvarez. The Cadastral Court granted their request

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Facts:

Background of the Cadastral Proceedings

• In April 1936, the Director of Lands filed a petition with the Court of First Instance of Leyte for the settlement and adjudication of titles over certain lands under the Ormoc Cadastre.
• Among the lands included was Lot No. 689 in the town (now City) of Ormoc, which measured approximately 338 square meters.

Default and Dismissal of the Case

• Despite proper notice and several motu proprio extensions granted by the court, no party claimed Lot No. 689 over a prolonged period.
• On April 1, 1942, an order of general default was issued, resulting in the dismissal of the cadastral proceeding as to this specific lot.

Early Attempts to Reopen the Case

• On July 22, 1940, Cecilia, Alicia, and Arturo Garcia Alvarez (the Fernandez Children) filed a petition with the Court of Appeals seeking to lift the general default order, asserting that they were the legitimate heirs of the deceased spouses Segundo Garcia Fernandez and Eulogia Alvarez.
• Their petition, which relied on Section 513 of the Code of Civil Procedure, was dismissed on technical grounds on September 27, 1940.

Reopening of the Proceedings by Another Set of Claimants

• On or about July 9, 1956, Constantino Alvarez, Jr., Casildita Alvarez de Muertegui, and Rosalia Alvarez Vda. de Tan (petitioners) filed a motion with the Cadastral Court to reopen the proceedings concerning Lot No. 689, claiming that they were the voluntary heirs of the deceased Garcia-Alvarez spouses and should inherit the property by succession.
• The Cadastral Court granted the motion, setting aside the 1942 general default order, and directed that the heirs of Segundo Garcia Fernandez (the Fernandez Children) be given the opportunity to present their own claims.

Trial and Issuance of Conflicting Decisions

• The trial was rescheduled several times; on the last scheduled day, the Fernandez Children failed to appear, which allowed the petitioners to present their evidence ex parte.
• On September 1, 1958, the Cadastral Court rendered a judgment adjudicating Lot No. 689 to Constantino Alvarez, Jr. and his co-movants, with the ruling emphasizing acquisition by prescription.
• Subsequently, on October 2, 1958, the Fernandez Children filed a petition for review alleging fraud, contending that the petitioners had shifted their claim from inheritance to a theory based on a flawed sale by Manuel Alvarez (purportedly from the Garcia-Alvarez spouses) without any supporting document, and challenging the standing of their lawyer, Atty. Cleto P. Evangelista.

Appellate Review and Development of the Case

• The Cadastral Court’s denial of the Fernandez Children’s petition for review (dated February 25, 1959) was later set aside by the Court of Appeals, which, on December 4, 1969, expressed serious doubts regarding the petitioners’ title claims.
• The Court of Appeals remanded the case for a new trial that allowed both parties to adduce evidence.
• The subsequent Cadastral Court decision again favored Constantino Alvarez, Jr. and his co-heirs by asserting the bar of laches against the Fernandez Children and affirming the acquisition by prescription.
• On February 5, 1982, the Court of Appeals reversed the Cadastral Court’s judgment, holding that the Fernandez Children were the rightful owners of Lot No. 689, and ordered the lot's registration in their name.
• Finally, Constantino Alvarez, Jr. and his co-heirs filed a petition for review on certiorari alleging errors in the application of evidence rules, the treatment of earlier decisions, and the invocation of doctrines such as laches and estoppel, which was ultimately denied by the Supreme Court.

Issue:

Determination of the Rightful Title

• Whether the rightful owner of Lot No. 689 is the party claiming inheritance from the Garcia-Alvarez spouses (the Fernandez Children) or the petitioners (Constantino Alvarez, Jr., et al.) who alternatively claimed acquisition by sale and prescription.

Inconsistencies in Claim Theories

• Whether the petitioners’ shifting assertions—from acquisition by inheritance to the claim of a sale involving Manuel Alvarez—undermine and render their claim legally untenable.

Validity of Procedural and Substantive Actions

• Whether the lack of a valid instrument of sale, as well as the procedural mishandlings (such as failure of the Fernandez Children to appear at trial and issues with their counsel’s standing), affect the determination of rightful ownership.
• Whether the petitioners’ invocation of the doctrine of res adjudicata, laches, and estoppel is proper, particularly when the alleged prior judgment was not on the merits and was not timely raised.

Issues on Possession and Prescription

• Whether Constantino Alvarez, Jr.’s role and presence as an administrator (as evidenced by tax declarations) amount to adverse possession sufficient to acquire title by prescription.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)