Case Digest (G.R. No. L-26100)
Facts:
City of Baguio, Reforestation Administration, Francisco G. Joaquin, Sr., Francisco G. Joaquin, Jr., and Teresita J. Buchholz v. Hon. Pio R. Marcos, Judge of the Court of First Instance of Baguio, Belong Lutes, and the Honorable Court of Appeals, G.R. No. L-26100, February 28, 1969, the Supreme Court En Banc, SANCHEZ, J., writing for the Court (Concepcion, C.J., Castro and Capistrano, JJ., did not take part; Reyes, Dizon, Makalintal, Zaldivar, Fernando, Teehankee and Barredo, JJ., concur).In April 1912 the Director of Lands instituted cadastral proceedings (Civil Reservation Case No. 1, GLRO Record No. 211, Baguio Townsite) in the Court of First Instance of Baguio; a final decision in that case was rendered on November 13, 1922, declaring the parcel in Plan Psu-186187 to be public land. On July 25, 1961 respondent Belong Lutes filed in the same cadastral court a petition to reopen those proceedings under Republic Act No. 931 (R.A. 931), claiming long adverse possession dating from Spanish times and lack of notice to his illiterate Igorot predecessors.
On December 18, 1961 private petitioners Francisco G. Joaquin, Sr., Francisco G. Joaquin, Jr., and Teresita J. Buchholz filed oppositions, alleging they held tree-farm leases from the Bureau of Forestry (agreements dated March–July 1959) covering portions of the parcel. The City of Baguio also opposed on May 5, 1962; the Reforestation Administration later adopted the City's motion to dismiss. The cadastral court initially denied private petitioners the right to intervene (May 8, 1962), relying on a March 9, 1962 declaratory judgment in Yaranon v. Castrillo (Civil Case 946) that declared such tree-farm leases null and void; after reconsideration the court allowed some participation (Sept. 14, 1962) but ultimately on August 5, 1963 dismissed the private petitioners' opposition and denied their motion for reconsideration (Nov. 5, 1963). Subsequent motions by the City and by petitioners were denied (Sept. 17, 1964).
All petitioners brought a petition for certiorari, prohibition and mandamus with preliminary injunction to the Court of Appeals (CA-G.R. No. 34909-R) on November 13, 1964; the Court of Appeals issued a writ of preliminary injunction on bond and, in a September 30, 1965 decision, held that petitioners were not bound by the earlier declaratory judgment but concluded that as lessees th...(Subscriber-Only)
Issues:
- Do private petitioners (tree-farm lessees) have the legal personality to intervene in and oppose a petition to reopen cadastral proceedings under R.A. 931?
- Must a petition to reopen cadastral proceedings under R.A. 931 be published in accordance with the Cadastral Act when the parcel is already embraced in prior cadastral proceedings filed by the Director of Lands?
- Does R.A. 931 permit the reopening of cadastral proceedings where the original proceedings were instituted more than forty years before approval of the Act but the judicial decision was rendered within the forty-year period—i.e., is Lutes’ July 25, 1961 ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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