G.R. No. L-25071 - Batchelder vs. Central Bank of the Philippines

Several civil cases (Civil Cases Nos. 3621, 3622, and 3623) involved plaintiffs claiming ownership and possession of agricultural lands located in the barrio of La Loma (now San Jose) in Caloocan, Rizal.
The plaintiffs alleged that they inherited these lands from their ancestors (Sixto Benin, Bonoso Alcantara, and Candido Pili) and had continuously, openly, adversely, and exclusively possessed and cultivated the lands from time immemorial.
The lands were later affected by the actions of the defendants, particularly J. M. Tuason & Co., Inc., which allegedly entered the areas with force and intimidation, demolished improvements, converted the lands into a subdivision, and collected rentals from lessees.

In a registration proceeding in LRC No. 7681, the Land Registration Court processed an application for registration of two parcels of land:

An amended plan was adopted during the proceedings to exclude certain areas already subject to other claims.

The amendment resulted in a slight increase in the computed area of Parcel 1 (approximately 27.10 square meters) compared to the original published plan.
The Court noted that no new land outside the originally published boundaries was added by the amendment.

On July 8, 1914, Original Certificate of Title (OCT) No. 735 was issued covering both parcels. Subsequent transfers and subdivisions were effected based on this title.

The trial court initially allowed the plaintiffs to proceed as paupers and later ruled in their favor by declaring:

The decision and subsequent Decree of Registration in LRC No. 7681 were null and void.
OCT No. 735 (and all transfer certificates derived therefrom) were declared null and void.
The plaintiffs were thus adjudged to be the rightful owners of the six specific parcels they claimed within the larger Parcel 1.

The trial court’s decision was based on alleged irregularities in the registration process:

The amended plan was not republished despite changes in the technical description and boundaries.
Differences in boundaries (especially on the southwestern side) and a minor discrepancy in area were cited as indicative of lack of jurisdiction.

Defendant J. M. Tuason & Co., Inc. contested the lower court’s findings, arguing that:

The Land Registration Court had proper jurisdiction because the amendment did not add new land beyond the original published plan.
The formal discrepancies were insubstantial and did not affect the integrity of the Torrens system.

The appeal raised multiple issues regarding the validity of the title, the correct interpretation of Act 496, and whether prior judgments (especially the decision in the Alcantara case, G.R. No. L-4998) should bar the current claims.
The case also involved conflicting claims regarding possession and the good faith status of J. M. Tuason & Co., Inc., as well as the rights of subsequent bona fide purchasers who acquired subdivision lots from the registered title.

Did the Land Registration Court have proper jurisdiction to amend the survey plan without republishing it, given that no new land was included beyond the originally published boundaries?
Does the slight discrepancy (an increase of 27.10 square meters) in the technical description of Parcel 1 justify nullifying the entire registration proceeding?

Was it proper for the trial court to declare OCT No. 735 and all derived transfer certificates null and void solely based on minor transcription errors and discrepancies in boundary descriptions?
Should the formal defects in the transcription (under Section 41 of Act 496) invalidate a certificate that otherwise faithfully reflects the court’s decree?

Does the prior Supreme Court decision in the Alcantara case (G.R. No. L-4998), which confirmed the validity and indefeasibility of OCT No. 735, operate as a bar against the current claims by the plaintiffs?
Are the actions for reconveyance or damages, based on challenging the registration, barred by prescription and the doctrine of res judicata?

Did J. M. Tuason & Co., Inc. acquire the title as a purchaser in good faith and for valuable consideration?
Should the rights of third party purchasers, who acquired subdivision lots and held valid transfer certificates derived from OCT No. 735, be protected despite the procedural disputes raised by the plaintiffs?