G.R. No. L-20354 - Samson, Jr. vs. Tarroza

A decision rendered on March 9, 1912, by Judge Norberto Romualdez of the Court of Land Registration confirmed the title of the Government of the Philippine Islands (now the Republic of the Philippines) to a parcel of land (identified as NOQP with an area of 81,870 square meters, more or less).
The Supreme Court affirmed this earlier decision on August 25, 1917.
On May 19, 1922, a decree and corresponding certificate of title were issued; however, instead of being in the name of the Government, the certificate was issued in the name of the Municipality of Malabon, Province of Rizal.

The Director of Lands, acting in representation of the Insular Government (and now the Republic of the Philippines), alleged that the substitution of the municipality’s name for that of the Government was the result of a clerical error.
A petition dated September 12, 1949, filed in Land Registration Case No. 4975, sought to compel the Municipality of Malabon to surrender its certificate of title to the Register of Deeds, so that a new certificate could be issued in favor of the Republic of the Philippines.

The Chief of the General Land Registration Office, through a report prepared by his chief surveyor and the head of the land titles division, maintained that the registration in favor of the Municipality of Malabon was neither irregular nor inadvertent.
The report noted that much of the original record (including the plan) had been destroyed during the wartime operations in Manila, and that the surviving documents did not indicate a casual mistake given the competence and diligence of the personnel involved.
Among the salvaged documents was a motion dated October 8, 1918, from Fiscal L. Garduno of Rizal, which, under the authorization of the Fiscal General, requested a writ of possession on the basis that the parcel had been ceded for school purposes, thereby suggesting a possible donation or intended donation.

The petition raised the issue of whether the court, specifically a judge of the Court of Land Registration (Judge Abaya), had the jurisdiction to compel the surrender of the existing certificate and order its reissuance in favor of the Republic after nearly 30 years had elapsed since its issuance.
The legal framework mentioned includes Section 29 and Section 112 of Act No. 496 (Land Registration Law), which provide for the conveyance and correction of the registered title under specific conditions, along with Section 38 that underscores the indefeasibility of titles after a lapse of one year.

Whether an error was committed in the entry of the decree and subsequent certificate of title in favor of the Municipality of Malabon instead of the Government.

Did a clerical error indeed occur during the issuance process?
What documentary or testimonial evidence supports or contradicts the occurrence of such an error?

Whether the petition under Section 112 of Act No. 496, which seeks correction of this alleged error, is a valid legal remedy in the context of the indefeasibility doctrine under the Torrens System.

Does Section 112 authorize the reissuance or correction of a certificate of title that was issued nearly 30 years earlier?
Can a court, operating under the powers conferred by Section 112, alter a substantive decree affecting registered rights?

Whether Judge Abaya, as a judge of the Court of Land Registration, possessed the jurisdiction to order the surrender of the existing certificate and to direct the issuance of a new certificate in favor of the Republic of the Philippines.

Was the action taken consistent with the limitations imposed on the court by the Land Registration Law and the principles underlying the Torrens System?
What implications does the elapsed time (nearly 30 years) have on the court’s jurisdiction and capacity to alter the title?