Title
Cabanas vs. Director of Lands
Case
G.R. No. L-4205
Decision Date
Mar 16, 1908
Julian Cabanas sought land registration; Director of Lands failed to oppose, deemed to admit claims. Supreme Court ruled appeal improper, upheld registration under Land Registration Act.
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Case Digest (G.R. No. L-4205)

Facts:

  1. Petitioner and Property Details:
    Julian Cabanas, a widower residing in San Isidro del Canipo, Leyte, filed an application with the Court of Land Registration to register a rural property he claimed as his absolute and unencumbered property. The property, occupied by him and his laborers, had an area of 18,741,675.20 square meters, divided into six portions, assessed at $3,404 (U.S. currency).

  2. Legal Proceedings:

    • The Director of Lands was served notice, and the Attorney-General appeared on his behalf.
    • On November 15, Cabanas amended his application, requesting that Act No. 926 be applied if his petition could not be granted under the Land Registration Act.
    • No written answer or opposition was filed by the Attorney-General to the application for registration.
  3. Judgment of the Lower Court:

    • On June 28, 1907, the court adjudicated the property to Cabanas and granted its registration under the Land Registration Act.
    • The Attorney-General, representing the Director of Lands, excepted to the decision, specifically contesting the registration of the sixth portion (829 hectares) acquired by adverse possession.
  4. Appeal and Default:

    • The Attorney-General filed a bill of exceptions and requested a new trial, arguing that the evidence did not justify the decision and that it was contrary to law.
    • The court denied the request, and the Attorney-General excepted to the denial.
    • Cabanas argued that the appeal was inadmissible because the Director of Lands had not filed an answer or opposition, implying admission of the allegations under Section 94 of the Code of Civil Procedure.

Issue:

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Ruling:

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Ratio:

  1. Admission by Default:
    Under Section 94 of the Code of Civil Procedure, the failure to file an answer or opposition results in the admission of all allegations in the application. Since the Director of Lands did not file an answer, he was deemed to have admitted Cabanas’ claims.

  2. Right to Appeal:
    An appeal can only be interposed by a party whose rights have been injured by the judgment. The Director of Lands, having made no claim of dominion or possession over the property, had no legal standing to appeal the decision.

  3. Legal Doctrine:
    The court reiterated the doctrine established in Roxas vs. Cuevas and Couto Soriano vs. Cortes, which holds that an opposition to a registration application must be based on a right of dominion or some other legal right. Absent such a claim, no appeal can be sustained.

  4. No Injury to Government Rights:
    The record showed no injury to the exclusive rights of the Government, and thus, the appeal was improperly admitted.


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