Title
Arceo vs. Varela
Case
G.R. No. L-2872
Decision Date
May 30, 1951
Dispute over land inheritance and sales; Supreme Court upheld adjudication of one lot but revoked another due to fraud and lack of due process, emphasizing judicial authority and co-ownership rights.
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Case Digest (G.R. No. L-2872)

Facts:

    Background of the Case

    • In the cadastral case No. 50 (with cadastral record No. 1820) before the Court of First Instance of Batangas, two separate lots were involved:
    • Lot No. 13956
    • Lot No. 14076
    • Original claims:
    • Lot No. 13956 was claimed by Jose Ma. Gabriel on behalf of himself and his sister, Carmen P. Gabriel, as an inheritance from their deceased mother, Trinidad Paterno de Gabriel.
    • Lot No. 14076 was claimed by the administrator of the intestacy of the deceased Mariano R. Varela, who asserted that the lot was acquired by the two Varela brothers (Mariano R. Varela’s intestate and his brother Andres R. Varela, then in America) through inheritance from their deceased mother.

    Sales and Subsequent Claims

    • The parties proceeded to sell the lots:
    • Jose Ma. Gabriel and Carmen P. Gabriel subsequently sold Lot No. 13956 to Melecio Arceo.
    • With court approval, the administrator of the intestacy of Mariano R. Varela sold his interest and participation in Lot No. 14076 to Melecio Arceo.
    • After purchasing the lots, Melecio Arceo filed his answer in the cadastral proceeding, claiming both lots and praying for adjudication in his favor.
    • Arceo later petitioned the court to have the decree and title issued in accordance with the now-final adjudication.

    Arrival of Opposition and Preliminary Proceedings

    • On September 1, 1947, Andres R. Varela, appearing through counsel, opposed Arceo’s petition.
    • Andres Varela asserted that he had acquired Lot No. 14076 through inheritance from his deceased father, mother, brother, and sister.
    • He prayed that the prior decision adjudicating the lots to Arceo be set aside and a new trial be ordered, alleging:
    • The decision was null and void due to fraud.
    • The decision was rendered by a judge who lacked authority to try and decide cadastral cases.

    Lower Court Proceedings and Issues of Notice

    • The hearing on the two lots was conducted without notice to any party except the provincial fiscal and Melecio Arceo.
    • On August 26, 1944, Judge Primitivo L. Gonzales rendered a decision, adjudicating both lots to Arceo and ordering the issuance of the corresponding decree of registration.
    • Subsequently, after the decision became final, further petitions and motions were filed:
    • Arceo petitioned for the issuance of the title on August 18, 1947.
    • Andres R. Varela opposed the petition on grounds of inheritance rights and alleged fraud.

Issue:

    Jurisdiction of the Lower Court

    • Whether Judge Primitivo Gonzales, a judge-at-large of the Court of First Instance of Batangas, had the authority to hear and decide the cadastral case given the existence of a specialized cadastral court.
    • Whether the judge’s assignment was limited or full, thus impacting his jurisdiction over the subject matter.

    Due Process and Notice

    • Whether failing to notify certain interested parties (such as Atty. Felix Villanueva, representing the administrator of Mariano Varela’s intestacy) of the hearing on Lot No. 13956 violated the principles of due process of law.
    • Whether the irregularities in notification affected the validity of the adjudication.

    Allegation of Fraud and Good Faith

    • Whether Melecio Arceo’s filing of a sworn claim for the entire Lot No. 14076, despite being aware (or constructively aware) that the sale deed conveyed only a right and participation in the lot, constitutes an act of bad faith amounting to fraud.
    • Whether such an act of bad faith justifies the reopening of the case, especially on the ground that fraud was evident prior to the issuance of the final decree of registration.

    Effect of Inheritance Claims

    • Whether the claims of Valentino Varela (on behalf of the intestacy and his own right) hold sufficient merit to contest the adjudication of Lot No. 14076.
    • How the inheritance issues impact the rights of the involved parties over Lot No. 14076.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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