Title
Leyva vs. Jandoc
Case
G.R. No. L-16965
Decision Date
Feb 28, 1962
Eligio and Eufemia Leyva are denied the right to independently intervene in a land registration case due to their subordinate interest as foreshore lessees and lack of a real right independent of the government's interest.
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Case Digest (G.R. No. L-16965)

Facts:

  • The case Leyva v. Jandoc, G.R. No. L-16965, was decided by the Supreme Court of the Philippines on February 28, 1962.
  • Petitioners Eligio T. Leyva and Eufemia L. Leyva opposed Manuela Jandoc's application for land registration in the Court of First Instance of Cotabato.
  • The land in question consisted of three parcels in Dadiangas, General Santos, Cotabato, identified as Lots Nos. 1, 2, and 3 of Plan Psu-124647.
  • The Leyvas filed their opposition on December 10, 1958, claiming adverse possession of a portion of the land in good faith since 1937.
  • Eufemia Leyva submitted a separate opposition, asserting ownership of another portion acquired from the National Resettlement and Rehabilitation Administration (NARRA).
  • The Bureau of Lands opposed the registration, arguing that the land was part of the public domain.
  • The trial court declared those who did not object to the registration as in default and continued with the hearing.
  • The Leyvas' counsel admitted their claim was based solely on a foreshore lease contract with the Secretary of Agriculture and Natural Resources.
  • The court ruled that the Leyvas could not act as independent oppositors but could collaborate with the provincial fiscal representing the government's interests.
  • The Leyvas' petitions for reconsideration were denied, leading them to file a petition for a writ of preliminary injunction with the Court of Appeals, which was dismissed.
  • The Leyvas subsequently appealed to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Court of Appeals' decision.
  • The Court held that the Leyvas could not independently intervene in the land registration case.
  • Their interest was deemed subordinate to the government's, a...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the principle that the Leyvas' claims depended on whether the land was part of the public doma...continue reading

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