G.R. No. 169461 - 1st Gas Power Corp. vs. Republic

Petitioner, First Gas Power Corporation, filed a petition for the original registration of two parcels of land (Lot Nos. 1298 and 1315) located in Brgy. Sta. Rita, Batangas City.
The lots, part of Cadastre 264 of the Batangas Cadastre, measured 4,155 and 968 square meters respectively.
The petition was docketed as Land Reg. Case No. N-1554 (LRA Rec. No. N-69624) with initial hearings held in the Regional Trial Court (RTC) of Batangas City, Branch 3.

During the initial hearing, only Prosecutor Amelia Panganiban, representing the Office of the Solicitor General (OSG), appeared aside from petitioner.
A Special Default Order was issued by the RTC, and the reception of evidence was delegated to the Branch Clerk of Court.
For the registration process, separate investigations and inspections were conducted by Department of Environment and Natural Resources (DENR) personnel, confirming that the subject lots fell within the alienable and disposable zone under the 1928 project schedule and were not part of any approved isolated survey.

Petitioner submitted documentary evidence including Deeds of Absolute Sale evidencing purchase from previous owners (Pio Benito Aguado for Lot No. 1298 and Glenn Manipis for Lot No. 1315).
Evidence showed that petitioner and its predecessors had maintained continuous, open, and peaceful possession of the lots, even before 1945.
It was also established that the subject lots had been declared for taxation under petitioner’s name, with corresponding realty taxes duly paid.
The RTC admitted all exhibits offered by petitioner since OSG did not contest the authenticity or validity of the documents.

On February 28, 2001, the RTC ruled in favor of petitioner, granting the application for registration, and directed the issuance of the corresponding decree by the Land Registration Authority (LRA) upon decision’s finality.
On July 17, 2001, petitioner filed a Manifestation with Motion, bringing to light an LRA Report (dated November 24, 1998) which indicated that the subject lots had been previously applied for registration and decided under Cad. Case No. 37.
In response, by means of an Amended Order dated September 4, 2001, the RTC set aside any decision affecting the subject lots in Cad. Case No. 37 and reiterated the issuance of a decree of registration favorable to petitioner.

Respondent (Republic of the Philippines through the OSG) filed a petition for certiorari challenging the RTC’s Amended Order, alleging grave abuse of discretion.
The CA, after receiving the necessary submissions including verification from the LRA, ultimately granted the respondent’s certiorari petition in a decision dated December 6, 2004, annulling and setting aside the RTC Decision, Amended Order, and the decree of registration.
The CA ruled that petitioner had the obligation to address the existence of the prior cadastral decision (Cad. Case No. 37) in its registration application.

Whether the Court of Appeals erred in annulling and setting aside the RTC Decision and Amended Order as well as the final decree of registration issued in favor of petitioner.

Whether petitioner, having been notified of an existing decision in Cad. Case No. 37, failed to demonstrate that such decision would not affect its claim of absolute ownership in fee simple.
Whether the amendment by the RTC, setting aside the prior cadastral decision based on a manifestation and motion, is justified given the principle of judicial stability and the in rem nature of land registration proceedings.