Facts:

On January 7, 1957, the spouses Bruno Papa and Valentina Agaceta applied for the registration of a parcel of land (Psu-59688) measuring 37,671 square meters at the Court of First Instance of Pangasinan, under Act 496. The application was published in the Official Gazette, and a hearing was scheduled for May 16, 1957, during which an order of general default was entered. On that same day, Baldomero Baldoz, the father of the appellant Superior Baldoz, filed a petition to lift the default order and submitted an opposition to the registration. The court granted the petition and reset the hearing for October 1, 1958. Unfortunately, prior to this hearing, Baldomero passed away, dying on July 28, 1957, but his son did not notify the court of his father's death. Consequently, the notice for the scheduled hearing was sent to Baldomero, which was returned unserved. On September 11, 1958, the original applicants were allowed to substitute the landowners from whom they had purchased the

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Facts:

Registration Application Initiation

• On January 7, 1957, spouses Bruno Papa and Valentina Agaceta—parents of the appellees—filed an application for registration of a parcel of land (Psu-59688) comprising 37,671 square meters, under Act 496, in the Court of First Instance of Pangasinan (Case No. 2215, L.R.C. Record No. 12389).
• The application was duly published in the Official Gazette and set for a hearing.

Entry of Default and Opposition

• During the hearing on May 16, 1957, an order of general default was entered in connection with the registration application.
• On the same day, Baldomero Baldoz—father of the appellant and the original oppositor—filed a petition to lift the general default and attached his opposition to the registration application.
• The court granted the petition and reset the hearing for October 1, 1958.

Complications Due to the Death of the Original Oppositor

• Prior to the reset hearing, Baldomero Baldoz died, yet his son Superior Baldoz (the appellant) did not inform the court of his father’s death.
• Consequently, the notice for the October 1, 1958 hearing was addressed to Baldomero Baldoz and was returned unserved.
• On September 11, 1958, appellees were allowed to substitute the original applicants from whom they purportedly purchased the land.

Proceedings at the October 1, 1958 Hearing

• At the scheduled hearing, the appellees and their counsel were present.
• Due to the absence of any oppositor (stemming from the issues surrounding Baldomero Baldoz’s death), the court permitted the appellees to present evidence in support of the application.
• Simultaneously, the court declared Baldomero Baldoz in default for non-appearance.

Motion for Substitution and Subsequent Proceedings

• On October 10, 1958, Baldomero Baldoz’s counsel filed a motion to set aside the order of default, arguing that the non-appearance was because of his death on July 28, 1957, and requested that his son Superior Baldoz be substituted as party-oppositor.
• This motion was denied on October 31, 1959. Superior Baldoz did not appeal this denial.
• On February 16, 1959, the court rendered judgment for registration of the parcel in favor of the appellees.
• Following the judgment, the decree was issued on May 4, 1959, and the Land Registration Commission promulgated Decree No. N-71779 on June 16, 1959, leading to the issuance of Original Certificate of Title No. 15264.

Post-Registration Developments and Litigation

• On June 17, 1959, appellees filed motions for issuance of writs of demolition and possession regarding the land.
• In response, Superior Baldoz filed an opposition to the petition for demolition of fences and a counter petition to stay the effects of the judgment; however, his opposition was denied on February 9, 1960.
• Approximately three weeks later, Superior Baldoz commenced a separate action (Civil Case No. D-1036) in the Court of First Instance of Pangasinan seeking annulment of the registration decision. His grounds were:
• Alleged reversible error by declaring his father (Baldomero Baldoz) in default despite a submitted written opposition.
• Denial of his motion for substitution as oppositor, which he claimed deprived him of his day in court.

Dismissal and Appeal

• Appellees moved to dismiss the complaint on several grounds: lack of legal capacity to sue, insufficiency of the complaint (no cause of action), and the cause being barred by prior judgment or the statute of limitations.
• On September 30, 1960, the lower court dismissed the complaint based on:
• The doctrine of res judicata, with the final judgment in Registration Case No. 2215 being binding.
• The nature of the action—a petition for review of a decree—requiring filing within one year from the issuance of the decree and being limited to cases based on fraud, as provided in Section 38 of Act 496.
• The present case is an appeal from the dismissal order.

Issue:

Jurisdiction and Substitution

• Whether the trial court lost jurisdiction over the oppositor (Baldomero Baldoz) once his death occurred and whether Superior Baldoz could have validly substituted for him as party-oppositor.
• Whether the failure to inform the court of Baldomero Baldoz’s death affected the validity of the default against him.

Timeliness and Proper Form of the Petition

• Whether Superior Baldoz’s action for annulment of the registration decision was properly filed within the one-year time limit required for petitions challenging a registration decree.
• Whether the petition should have been filed as a motion within the registration proceeding rather than as a separate action.

Res Judicata and Finality of Registration Proceedings

• Whether the judgment rendered in the registration proceedings is res judicata and binding on the parties, precluding Superior Baldoz’s separate suit for annulment.
• Whether registration proceedings, being in rem, can be reopened or challenged beyond the prescribed period and without a fraud allegation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)