G.R. No. 123361 - Cacho vs. Court of Appeals

Two parcels of land situated in what was then Lanao, Moro Province, within the limits of Military Reservation No. 43 ("Camp Overton") were the subject of registration.
In GLRO Record No. 6908, a small parcel was purchased by Doña Demetria Cacho from Gabriel Salzos, whose title was based on a deed of sale executed by Alanga (acting for her husband, Dorondon).
Before registration could be admitted in Case No. 6908, the trial court ordered the submission of a deed from Dorondon renouncing his rights over the parcel.
In GLRO Record No. 6909, involving a larger parcel measuring approximately 37.87 hectares, the land was acquired from the Moro Datto Bunglay.

Datto Bunglay’s claim was partly based on an inheritance from his uncle, Datto Anandog, and partly on his own possession and cultivation.
The trial court, noting that only a portion of the large parcel was sufficiently cultivated by the deceased Datto Anandog, ruled that Doña Demetria Cacho was the owner only of the cultivated section, denying her application over the remainder.

An ocular inspection at Camp Overton was conducted on December 10, 1912, to fix the limits of the cultivated portion, with stakes set to mark the boundaries for a new survey.
The 1912 decision, including conditions (submissions of the deed and new survey), was later affirmed in Cacho v. Government of the United States (28 Phil. 616 [1914]) with final decisions being reserved pending compliance.

On June 29, 1978, Teofilo Cacho, as the son and sole heir of the late Doña Demetria Cacho, filed a petition under Republic Act 26 for the reconstitution of two original certificates of title corresponding to GLRO Record Nos. 6908 and 6909.
The petition was opposed by the Republic of the Philippines, the National Steel Corporation (NSC), and the City of Iligan.
The lower court initially dismissed the petition for lack of evidence to establish the existence of the titles and indicated that the proper remedy was a re-issuance of decrees, given that Decrees No. 10364 and 18969 had already been issued.
An omnibus motion for leave to file an amended petition was filed but denied, leading to a separate appeal (Teofilo Cacho v. Hon. Manindiara P. Mangotara, G.R. No. 85495) which was remanded back to the lower court to accept the amended petition.
The lower court eventually accepted the amended petition and, on June 9, 1993 (RTC-City of Iligan, Branch 1), decreed the reconstitution and reissuance of Decrees No. 10364 and 18969.
In the consolidated answer/opposition, respondents raised several defenses including claims of jurisdictional infirmities, laches, nonexistence or fictitious nature of the petitioner, and alleged irregularities in the issuance of the decrees.

Respondents (Republic of the Philippines, NSC, and City of Iligan) appealed the lower court’s decision on several grounds, contending:

The petition for reconstitution suffered from fatal jurisdictional issues and was being prosecuted by a party lacking a lawful interest.
Conditions set forth in the 1914 Cacho decision (e.g., submission of a deed and a new survey) had not been complied with or proven, making the decrees subject to reopening.
The petition was barred by laches, which, according to them, should prevent the petitioner from asserting his claim after such a protracted period.
The petition should be dismissed because it sought reissuance over a parcel of land already owned by the City of Iligan under a later presidential proclamation.

The Court of Appeals, while acknowledging elements such as the issuance and existence of the decrees (with dates confirmed from the LRC Registry), reversed the lower court’s decision and dismissed the petition on several substantive grounds, including the necessity for a new survey in Case No. 6909 and the application of laches.

Whether the petition for reconstitution and reissuance of the decrees could properly proceed given the alleged jurisdictional infirmities and doubts about the petitioner’s real interest.
Whether Teofilo Cacho, as the sole heir of Demetria Cacho, was sufficiently established as the real party in interest.

Whether the mandatory conditions stipulated in the 1914 decision (e.g., submission of the deed from Dorondon and the completion of a new survey) had been met or were still subject to reexamination.
Whether the existence of final decrees in the earlier proceedings precluded reopening the matter to examine compliance with such conditions.

Whether the doctrine of laches could bar the petitioner’s claim for the reissuance of the decrees despite the nature of land registration proceedings being declaratory and ministerial.
The impact of laches on the petitioner’s right to have the decrees reconstituted after a considerable period.

Whether reopening the matter by requiring further conditions (such as a new survey) would undermine the finality and conclusiveness of the decrees under the Torrens system.
Whether the established doctrine of res judicata prevents reassessment of matters that have already been adjudicated and finalized.