G.R. No. 235965-66 - Figueroa vs. Sandiganbayan, Special 3rd Division

Julian Cabanas, a widower residing in the pueblo of San Isidro del Canipo, Province of Leyte, applied for the registration of a rural property.
The property, which measures approximately 18,741,675.20 square meters, consists of six portions and was last assessed at $3,404 (United States currency) for land tax purposes.
The title deeds accompanying the application contained pertinent details including the manner of acquisition, boundaries, and a plan and description of the property.

Cabanas filed his application with the Court of Land Registration, asserting his absolute ownership based on unencumbered title deeds.
The application was initially served upon the Director of Lands.
A motion was later presented on November 15, 1907, to amend the application so that, if necessary, Act No. 926 could be applied in lieu of the Land Registration Act provisions, particularly regarding the portion acquired by adverse possession.

The Attorney-General, appearing on behalf of the Director of Lands, did not offer any written answer or opposition to the petition for registration.
In accordance with Section 94 of the Code of Civil Procedure, the failure to file an answer resulted in the allegations of Cabanas being deemed admitted.
The court, after considering the oral and documentary evidence, rendered judgment on June 28, 1907, adjudicating the property in favor of the petitioner.
Special attention was given to the sixth and last portion of the land—comprising 829 hectares, 81 ares, and 19 centares—which was acquired by adverse possession and was to be registered under Section 54, paragraph 6, of Act No. 926.

The Attorney-General, representing the Director of Lands, excepted to part of the decision—specifically the registration under Act No. 926 for the adverse possession-acquired portion—and indicated an intention to file a bill of exceptions for the review of that portion.
Additionally, the Attorney-General requested a new trial on the ground that the evidence was insufficient and the judgment was contrary to law.
The petitioner objected to the appeal on the basis that the Attorney-General had not opposed the registration in any substantive or procedural manner, thus effectively admitting all of Cabanas’ allegations by default.
The case was ultimately submitted to the appellate court through the bill of exceptions, raising the issue of whether the appeal was proper given the lack of a formal defense by the government.

Section 94 of the Code of Civil Procedure mandates that a failure to answer in writing results in all unchallenged allegations being deemed admitted.
Sections 35 and 36 of Act No. 496, as amended by Act No. 1699, authorize the entering of a decree confirming the title when a defendant fails to appear or answer, resulting in a default order.
The legal framework underscores that a party included in a general default cannot later oppose a judgment on the ground that was already accepted by inaction.

Whether the appeal interposed by the Attorney-General (on behalf of the Director of Lands) was valid given that no answer or opposition was tendered to the registration application.
Whether the lack of a written defense from the Attorney-General, which led to the default ruling, negates the basis for an appeal.

Whether the registration of the property, particularly the portion acquired by adverse possession, was justified under the applicable statutory framework (Land Registration Act and Act No. 926).
Whether the court below correctly applied Sections 35 and 36 of Act No. 496, thereby rendering the registration granted to Julian Cabanas conclusive and unassailable.

Whether the government, through the Attorney-General, sustained any genuine legal injury or loss of rights that would justify an appeal.
Whether the doctrine requiring a party’s own legal rights to be prejudiced (as established in related cases) applies, thereby rendering the appeal impermissible in this context.