Case Digest (G.R. No. 107764)
Facts:
Edna Collado et al. v. Court of Appeals and Republic of the Philippines, G.R. No. 107764, October 04, 2002, First Division, Carpio, J., writing for the Court. Petitioners are a group of persons (collectively, petitioners) who sought judicial confirmation of an imperfect title over a 120.0766-hectare parcel in Barangay San Isidro (Boso-boso), Antipolo, Rizal (the “Lot”); respondents are the Court of Appeals, the Republic of the Philippines (through the Director of Lands), and several intervenors including Bockasanjo ISF Awardees Association, Inc. and named individuals.On April 25, 1985 petitioner Edna T. Collado filed an application for registration of the Lot in the land registration court, attaching Survey Plan Psu-162620 which bore a technical note stating the survey was inside the Marikina Watershed (IN-12). An amended application adding co-applicants was filed March 24, 1986, and additional claimants later joined. The Republic and the Municipality of Antipolo filed oppositions; the land registration court issued a general default order against the world except the oppositors.
At the land registration court petitioners presented evidence of long possession tracing to a 1902 survey in the name of Sesinando Leyva and multiple transfers, tax declarations, cultivation, and tree planting. Oppositors failed to present evidence at scheduled hearings; the court submitted the case for decision on petitioners’ evidence and, in a decision dated January 30, 1991 (penned by Judge Patricio M. Patajo), confirmed petitioners’ imperfect title and directed issuance of the decree of registration. Petitioners sought issuance of the decree in April–May 1991; the land registration court ordered the Land Registration Authority to issue the decree in May 1991.
The Solicitor General, claiming the Lot was not alienable and disposable but part of the Marikina Watershed Reservation (established by Executive Order No. 33), filed in the Court of Appeals on August 6, 1991 a Petition for Annulment of Judgment under Section 9(2) of B.P. Blg. 129. The Court of Appeals granted a restraining order (August 8, 1991) enjoining execution of the land registration court’s decree. Meanwhile, on November 29, 1991 Bockasanjo ISF Awardees Association, Inc. (holders of DENR stewardship certificates under the Integrated Social Forestry program) moved to intervene in the Court of Appeals proceedings asserting awardees’ stewardship and Proclamation No. 585 (1990) that excluded certain areas from EO No. 33 for ISF purposes.
In a decision dated June 22, 1992 (Thirteenth Division, CA-G.R. SP No. 25597, J. Arturo B. Buena, ponente), the Court of Appeals granted the Solicitor General’s petition, declared the land registration court’s January 30, 1991 decision null and void for l...(Subscriber-Only)
Issues:
- Whether the Court of Appeals erred in giving due course to the Republic’s petition for annulment of judgment filed after the land registration court’s decision had become final.
- Whether the Court of Appeals erred in admitting the intervenors’ petition for intervention filed after the land registration court rendered judgment.
- Whether the Court of Appeals erred or gravely abused its discretion in reversing the trial court’s confirmation of pe...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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