G.R. No. L-32163 - People vs. Alonzo

The case arises from a cadastral proceeding (Cadastral case No. 63 of the Court of First Instance of Tayabas) involving the adjudication of title to lands covered by lot No. 8610.
Haw Pia, one of the claimants to the land, launched a petition for certiorari and prohibition against actions taken in the lower court.

Respondent Judge Roman A. Cruz of the Court of First Instance of Tayabas issued an order appointing a receiver to take possession of lot No. 8610 during the pendency of an appeal by one of the adverse claimants.
The receiver's appointment was intended to secure possession and manage the property until the resolution of the underlying dispute regarding title.

Haw Pia contended that the order appointing the receiver was issued without jurisdiction, as no law expressly empowers a cadastral court to appoint a receiver in such proceedings.
The petitioner sought the nullification of the receivership order on the ground that it was beyond the scope of the court’s authority in a cadastral proceeding.

A motion for contempt was also raised by the petitioner against respondent Aurelia Altea and receiver Andres Parco.
The allegation was that they had violated a preliminary injunction previously issued by the Supreme Court.
The affidavits on record did not substantiate the guilt of Aurelia Altea.
It was demonstrated that receiver Andres Parco acted in good faith by ceasing possession and delivering the property’s fruits to the Chief of Police once he understood the true effect of the Court’s order.

The petition raised a key issue regarding the jurisdiction of courts in cadastral cases, noting that such courts have a special and limited mandate to adjudicate titles alone.
The petition underscored that questions of possession, unless merely incidental to the title, fall outside the court’s competence in a cadastral proceeding.

Does a Court of First Instance in a cadastral proceeding have the jurisdiction to appoint a receiver when such a remedy is not explicitly granted by law?
Is the appointment of a receiver an ancillary remedy permissible under the limited scope of power vested in a cadastral court?

Should the order appointing a receiver be set aside on the ground that it was issued without jurisdiction?
How does the limitation on the jurisdiction of cadastral courts affect the power to address issues regarding possession, separate from the title itself?

Was the motion for contempt against Aurelia Altea and Andres Parco properly sustained by the evidence on record?
Were the acts of the receiver, as performed in good faith, sufficient to warrant dismissal of the contempt proceedings?