Facts:

The case "Santiago Arenas and his wife Tomasa Rosario vs. Dionisio Zamora et al." (G.R. Nos. 41550, 41551) was tried together for the registration of lots located in Binmaley, Pangasinan. The respondents, Santiago Arenas and Tomasa Rosario, applied for the registration of Lot 2 as part of their claim to certain parcels of land, which they asserted they had possessed. Conversely, the appellants, Dionisio Zamora and others, sought registration of the same Lot 2 under a separate application (case No. 15136) with claims against it. The trial court found no adverse claimant for Lot 1 in Arenas' favor and ruled in favor of Arenas regarding the registrations requested for Lot 2. The court dismissed Zamora's application for Lot 2, overruling some of the oppositions filed against the application by the Zamoras while sustaining others. The trial court’s decision hinged greatly on the findings of two appointed commissioners who performed an ocular inspection of the contes

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Facts:

Procedural Background

• Two cases were tried together: Case No. 15116 and Case No. 15136.
• In Case No. 15116, Santiago Arenas and his wife Tomasa Rosario applied for the registration of lots Nos. 1 and 2 under Plan PSu-94351.
• In Case No. 15136, Dionisio Zamora and others applied for the registration of lots Nos. 1 and 2 under Plan PSu-94350.
• Lot No. 1 in Case No. 15116 was uncontested and not involved in the appeal; however, Lot No. 2 in Case No. 15116 corresponds to the same land as Lot No. 2 in Case No. 15136.

Decision of the Lower Court

• In Case No. 15116, the trial court ordered the adjudication and registration of both lots in favor of Santiago Arenas and Tomasa Rosario.
• In Case No. 15136, the court:
• Dismissed the application with respect to Lot No. 2.
• Overruled the oppositions of Vicente, Irineo, and Leonardo (all surnamed De Guzman).
• Sustained the opposition of Jose Salvador and Lamberto Arenas, ordering the adjudication and registration of Lot No. 1 in portions, with the contested parts excluded as delineated on the approved plan PSu-94350.
• The adjudication in Lot No. 1 was detailed with a pro indiviso division among several parties, including Dionisio Zamora, Apolonio Zamora, Braulia Zamora, Maria Rosario, Eusebio Ferrer, Felicisimo Concepcion, Perfecto de Guzman, Cesareo de Guzman, Valeriana de Guzman, and Jacinta de Guzman.
• Upon finality of the decision and approval of an amended plan by the Director of Lands, corresponding decrees were to be issued.

Ocular Inspection and Commission Appointment

• During the proceedings, an adverse claimant’s attorney in Case No. 15136 requested an ocular inspection to ascertain the existence of physical boundary markers such as trees, fences, and pilapils (posts or markers).
• The attorneys for the Zamoras opposed the inspection, arguing that it would be unnecessary and economically unjustifiable given the small value of the land.
• Despite the objection, the court ordered an ocular inspection by appointing commissioners Juan C. Ramos and Mauro Ordoiia, assisted by surveyor Roman Sison and later by Mariano Celis.
• The commissioners and surveyor were tasked with verifying boundary markers, including the line of trees, presence of pilapils, fences, and additional physical structures (such as a hut built by Santiago Arenas) along the dividing lines of the contested properties.
• The inspection was conducted on October 21, 1933, with the reports thereafter filed on October 23 and 24, 1933.
• Notably, the attorney for the appellants was not notified of these reports, nor was there an opportunity for cross-examination of the findings presented by the commissioners and surveyor.

Reliance on the Findings

• The trial judge placed significant reliance on the findings contained in the reports of the appointed commissioners and the surveyor.
• The reports were accepted as the factual basis of the decision without having the commissioners or the surveyor testify in open court.
• The trial court’s approval of the findings was expressed in statements that emphasized the impartiality of the officers, their oath-bound duty, and the clear, mute evidence they observed regarding the boundary lines.

Notice and Opportunity to Object

• Under Rule 31 of the Rules of Courts of First Instance, parties were entitled to be notified of the filing of commissioners’ reports and to have ten days to file exceptions or objections.
• The lower court’s procedures did not afford the appellants this opportunity, as the reports were filed and adopted without notifying the legal representatives of the opposing party.

Resulting Controversies

• The appellants (Dionisio Zamora and others) raised four specific assignments of error, focusing on the improper delegation of judicial functions, the acceptance of allegedly inadmissible evidence, and the resulting injustice in adjudicating the land registration.
• The controversial use of commissioners’ findings, not subjected to cross-examination, became the central fact in the appellate dispute.

Issue:

• Whether the trial judge erred in delegating judicial functions to his own stenographer and interpreter by appointing them as commissioners (referees) for an ocular inspection, and thereafter adopting their findings without further opportunity for objection or cross-examination of their testimony.
• Whether the lower court was justified in determining, based solely on the commissioners’ reports, that the opponents (Santiago Arenas, Lamberto Arenas, and Jose Salvador) had possessed the disputed portions as bona fide owners under the requirements for acquisition by prescription.
• Whether the trial court erred in deducing from the commission’s findings that the opponents had sufficiently proven ownership in fee simple of the contested portions.
• Whether the lower court’s order, which excluded the contested portions from the appellants’ application and did not adjudicate the lots in their entirety in favor of the appellants, was erroneous.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)