Title
Director of Lands vs. Register of Deeds for the Province of Rizal
Case
G.R. No. L-4463
Decision Date
Mar 24, 1953
A dispute arises over a parcel of land in Malabon, Rizal, as the Director of Lands seeks to correct an error in the issuance of a certificate of title, leading the court to rule that the proper remedy is an ordinary action for reconveyance or damages rather than a petition to correct clerical errors.
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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

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