Case Digest (G.R. No. L-30773)
Facts:
- The case involves a parcel of land in the municipality of Malabon, Province of Rizal.
- In 1912, a decision was handed down confirming the title of the Government of the Philippine Islands to the land.
- However, the decree and certificate of title were issued in the name of the municipality of Malabon instead of the Philippine Government.
- The Director of Lands filed a petition to correct this error and order the municipality of Malabon to surrender the certificate of title and issue a new one to the Republic of the Philippines.
Issue:
- (Unlock)
Ruling:
- The court rules that the proper remedy is not through a petition to correct clerical errors, but through an ordinary action for reconveyance or damages.
- The court reverses the appealed order and advis...(Unlock)
Ratio:
- Even if there was an error in the entry of the decree and certificate of title, the proper remedy is not through a petition to correct clerical errors.
- The court emphasizes that the registration of land in the name of a party other than the registration applicant is not necessarily strange or anomalous, and can be in order.
- The court highlights that the procedure followed in this case and the o...continue reading
Case Digest (G.R. No. L-30773)
Facts:
The case of Director of Lands v. Register of Deeds for the Province of Rizal involves a dispute over a parcel of land in Malabon, Rizal. The Director of Lands, representing the Insular Government of the Philippine Islands (now the Republic of the Philippines), seeks to correct an error in the issuance of a certificate of title. The certificate of title was issued in the name of the municipality of Malabon instead of the Philippine Government. The Director of Lands files a petition to correct the error and requests that the municipality of Malabon surrender the certificate of title and a new one be issued to the Republic of the Philippines.
Issue:
The main issues raised in the case are: 1) whether an error was committed in the entry of the decree and certificate of title in favor of the municipality of Malabon, and 2) whether relief lies by petition under section 112 of Act No. 496, known as the Land Registration Law.
Ruling:
The court rules that even if a clerical mistake was made in the entry of the decree and certificate of title, the court may not recal...