Title
Ignacio vs. Basilio
Case
G.R. No. 122824
Decision Date
Sep 26, 2001
A 1941 land registration case involving overlapping titles, jurisdictional disputes, and laches, culminating in the Supreme Court affirming the dismissal of petitioner's claims due to delay and third-party rights.

Case Digest (G.R. No. 122824)

Facts:

Aurora F. Ignacio v. Valeriano Basilio, G.R. No. 122824, September 26, 2001, Supreme Court Second Division, Quisumbing, J., writing for the Court.

Petitioner Aurora F. Ignacio (hereafter petitioner) traces title from predecessors-in-interest who, with 73 others, filed consolidated applications in 1941 as Land Registration Case (LRC) No. 1489 in the then Court of First Instance (CFI) of Rizal, Branch 1, covering Lots 1–29 of Plan Psu-107981. Proceedings were interrupted by the Pacific War and the records later reconstituted; on July 12, 1966 the trial court adjudicated the 29 lots in various undivided shares to barrios and private heirs, and on March 31, 1967 denied motions for reconsideration. Appeals followed (CA-G.R. No. 41049-R).

In 1969 petitioner acquired the rights of the Heirs of Hilarion Ruiz. While the appeal in CA-G.R. No. 41049-R was pending, private respondent Valeriano Basilio filed LRC No. N-164-M on March 2, 1971 in the CFI of Rizal, Branch 15, seeking registration of portions of Lots 3, 6 and 25 (later designated Lots 1, 2, 5 and 6 of Plan Psu-235385). On August 13, 1971 Branch 15 entered judgment in Basilio’s favor; on September 21, 1971 the court ordered issuance of decree and OCT No. 9010 pursuant to Decree No. N-137158. Basilio thereafter subdivided and sold portions to purchasers who relied on his title.

Separately, on April 27, 1972, the Heirs of Macario Omana and others (including petitioner) filed LRC No. N-7824 in CFI, Branch 13; on December 18, 1974 Branch 13 adjudicated several specific lots and issued OCTs (including for Lots 26 and 27 in petitioner’s favor). Meanwhile, on June 17, 1975 the Court of Appeals issued a decision in CA-G.R. No. 41049-R modifying the LRC No. 1489 judgment; motions for reconsideration were denied October 23, 1981.

On March 1, 1988 petitioner moved for a final decree of registration in LRC No. 1489 (excluding properties already adjudicated in LRC No. N-7824). After the RTC ordered issuance of the final decree on April 21, 1988, petitioner discovered portions of Lots 3, 6 and 25 had been titled to Basilio. Petitioner then filed CA-G.R. SP No. 16830 seeking annulment of the decree in LRC No. N-164-M on grounds Branch 15 lacked subject-matter jurisdiction because LRC No. 1489 had earlier acquired jurisdiction over the same property.

The Court of Appeals, in a decision dated March 20, 1995, dismissed petitioner’s action, holding inter alia that (1) innocent third-party purchasers had acquired substantial portions; (2) laches barred petitione...(Pro-only)

Issues:

  • Did the Court of Appeals err in not declaring the proceedings in LRC No. N-164-M before the defunct CFI of Rizal, Branch 15, null and void for lack of subject-matter jurisdiction?
  • Is petitioner’s action barr...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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