G.R. No. 209906 - Coca-Cola Bottlers Philippines, Inc. vs. Menez

In 1909, a survey was made for Santiago Quimson covering a parcel in Barrio Totopiac, Orani, Bataan with an approximate area of 687,360 square meters. The survey plan was designated as I-1054.
The land was registered on September 18, 1909, with Original Certificate of Title (OCT) No. 46 issued to Quimson.
A later cadastral survey (February 1919 to March 1920) increased the area by 17,053 square meters and designated the lot as Lot No. 363 of the Orani Cadastre with a total area of 704,413 square meters.
The cadastral proceedings confirmed Quimson’s title, leading to the issuance of Transfer Certificate of Title (TCT) No. 723 in lieu of the original certificate.
The lot was subdivided into:

Lot No. 363-A (209,250 square meters) for which TCT No. 760 was issued.
Lot No. 363-B (495,163 square meters) later acquired by Eligio Naval with TCT No. 787 issued on July 6, 1926.

In December 1916, a parcel in Barrio Bagumbayan, Hermosa, Bataan was surveyed for Potenciano Gabriel under Survey Plan Psu-9742, covering 2,729,712 square meters.
It was later amended (Plan Psu-9742-Amd) after excluding overlapping portions with the lot surveyed for Quimson, reducing the area by 293,432 square meters to 2,436,280 square meters.
OCT No. 1264 was issued in Gabriel’s name on November 1, 1918, reflecting the reduced area.
A subsequent cadastral survey of Hermosa further reduced the area of Potenciano Gabriel’s land: the land became Lot No. 557 with an area of 2,096,433 square meters, a reduction of an additional 339,847 square meters.
The partition of Gabriel’s estate on August 28, 1947 was based on Plan Psu-9742-Amd and OCT No. 1264, not on the smaller Lot No. 557.

Petitioners, being the heirs of the late Potenciano Gabriel and alleged joint co-owners of a 1,196-square-meter fishpond in Hermosa, Bataan, filed a complaint in Civil Case No. 2283.
They claimed:

That the land was usurped by the late Eligio Naval, an adjoining owner, despite an allegation that it was merely loaned to Naval for dike and water control purposes.
Private respondents (Petrita Pascual and Rudyardo Santiago, administratrix and administrator of Eligio Naval’s estate) continued to possess and use the property after Don Potenciano’s death on February 17, 1943.

It was identified that the disputed 1,196-square-meter portion was part of Lot No. 363-B of the Orani Cadastre, already in the continuous possession of Naval.

The Court of First Instance of Bataan, in its decision dated August 29, 1958, dismissed the complaint on the grounds of prescription and laches.

It ordered the petitioners to surrender the owners’ copies of the certificates of title.
It also imposed an order for the payment of costs.

The Court of Appeals, in its May 31, 1966 decision, affirmed the lower court’s ruling without finding any error.
The petitioners’ Motion for Reconsideration filed thereafter was denied on July 7, 1966.
Subsequent proceedings included:

The filing of a petition for review on certiorari with this Court.
Motions for substitution of parties (with Petrita Pascual seeking to replace herself with spouses Florencio Lucio and Conchita Gandan).
The inclusion of new parties following the court’s resolution on March 7, 1967.
Submission of briefs by both petitioners and respondents, with the case finally being considered for decision without a petitioner’s Reply Brief.

Petitioners claimed that the correction of the technical description in Plan Psu-9742-Amd, which reduced the area by 336,901 square meters (to conform with Lot No. 557 of the Hermosa Cadastre), amounted to a grave error.
They contended that such correction:

Deprived them of their substantial rights as registered owners.
Constituted a reopening of a final decree of title after the lapse of the one-year statutory period.
Amounted to a collateral attack on the title.

The contention was that the correction impaired their property rights protected under the Land Registration Act and related statutory provisions.

The jurisdiction of the court is limited to correcting technical errors in the description of lands, provided there is no impairment of the substantial rights of the registered owner.
Such corrections do not reopen the registration decree nor create a new title.

Pamintuan v. San Agustin (43 Phil. 561, 1922).
Timbol v. Diaz (44 Phil. 589-590, 1932).
Simoan v. Sorongan (136 SCRA 407, 1985).
Additional cases such as Gustilo v. Maravilla and Legarda and Prieto v. Saleeby supporting the principle that technical corrections do not amount to a reopening of title or an unjust deprivation of rights.

Moreover, petitioners’ failure to assert their claim within twenty (20) years was deemed fatal on the ground of laches.

Whether the courts have jurisdiction to order the correction of an erroneous technical description (as evidenced in Plan Psu-9742-Amd) to conform with the actual cadastral lots (Lot No. 557 of Hermosa Cadastre and Lot No. 363 of Orani Cadastre).
Whether such judicial correction constitutes an impermissible reopening of the registration decree, thereby depriving the registered owner of their title and substantial rights.
Whether the failure of the petitioners to prosecute their claim within a reasonable period (claiming laches and prescription) bars their right to recovery of the disputed portion.