Case Digest (G.R. No. 25067)
Facts:
- The case Buenviaje v. Director of Lands (G.R. No. 25067) was decided by the Supreme Court of the Philippines on February 23, 1927.
- Tranquilino Buenviaje sought registration for an eight-hectare parcel of land located in Anilao, Mabini, Batangas.
- His application encountered opposition from the Director of Lands, several individuals, and the provincial fiscal of Batangas.
- The Court of First Instance of Batangas issued a partially favorable ruling for Buenviaje, leading him to file an appeal.
- The case had previously been deliberated with unpublished decisions by the Supreme Court's Second Division in 1926.
- The final ruling was divided, with three justices in favor of Buenviaje and two dissenting.
- Buenviaje's counsel submitted a petition for reconsideration on January 6, 1927, challenging the authority of three justices to render a judgment.
Issue:
- (Unlock)
Ruling:
- The Supreme Court determined that three members of the Supreme Court in division are authorized to issue a judgment.
- The provision in the Administrative Code permitting such a decision was aff...(Unlock)
Ratio:
- The court's reasoning was grounded in the interpretation of the legislative framework governing the Supreme Court's functions.
- It referenced United States vs. Limsiongco, which clarified that the Supreme Court operates as a unified entity, even when divided.
- The court differentiated between jurisdictional issues and procedural matters, asserting that the number of justices required for a decision is a procedural concern.
- It emphasized that "jurisdiction" relates to the court's authority over l...continue reading
Case Digest (G.R. No. 25067)
Facts:
The case of Buenviaje v. Director of Lands (G.R. No. 25067) was adjudicated by the Supreme Court of the Philippines on February 23, 1927. The applicant-appellant, Tranquilino Buenviaje, sought the registration of a parcel of land measuring approximately eight hectares, situated in the barrio of Anilao, within the municipality of Mabini, Province of Batangas. His application faced opposition from the Director of Lands, several individuals, and the provincial fiscal of Batangas, who represented the provincial interests. The Court of First Instance of Batangas issued a decision that was only partially favorable to Buenviaje, leading him to file an appeal against the ruling. Prior to this, the case had undergone deliberation through a series of unpublished decisions rendered by the Second Division of the Supreme Court on June 26, November 15, and December 24 of the previous year, 1926. Ultimately, the decision was split, with a majority of three justices supporting Buenviaje's claim while two justices dissented. Following this division, Buenviaje's legal counsel submitted a petition for reconsideration on January 6, 1927, raising a pivotal question regarding the authority of only three justices to render a judgment, arguing that the Organic Law necessit...