Facts:

The case involves Geronimo Miraflor as the petitioner against Hon. Eladio R. Leano, Aurelia Miraflor, and Hermenegilda Tan as respondents. Vicente Miraflor, a resident of Santa Cruz, Zambales, passed away intestate in 1927, leaving behind his second wife, Hermenegilda Tan, and two children: Aurelia Miraflor, his daughter with Hermenegilda, and Antero Miraflor, his son with his deceased first wife. Prior to his death, Vicente initiated a registration case (Case No. 140, G. L. R. O. Record No. 32440) for a parcel of land measuring 60,775 square meters, which he acquired during his first marriage. After Vicente's death, the court decreed the registration of the land in favor of his two children, resulting in the issuance of Original Certificate of Title No. 2889.

In 1941, Antero Miraflor died without any heirs. Subsequently, on May 15, 1951, Aurelia Miraflor and her mother, Hermenegilda Tan, filed a petition in the same registration case, asserting that Antero had no heirs...

Facts:

1. Background of the Case
   Vicente Miraflor of Santa Cruz, Zambales, died intestate in 1927. He was survived by his second wife, Hermenegilda Tan, and their only child, Aurelia Miraflor. He also had a child, Antero Miraflor, from his deceased first wife.

2. Land Registration Proceedings
   Before his death, Vicente Miraflor initiated a land registration case (No. 140, G. L. R. O. record No. 32440) for a parcel of land measuring 60,775 square meters, which he acquired during the lifetime of his first wife. After his death, the land was registered in the names of his two children, Antero and Aurelia Miraflor, and Original Certificate of Title No. 2889 was issued in their names.

3. Death of Antero Miraflor
   Antero Miraflor died without issue in 1941. On May 15, 1951, Aurelia Miraflor and her mother, Hermenegilda Tan, filed a petition in the same land registration case, claiming that Antero had no heirs except Aurelia and that there were no known claims against his estate. They sought the cancellation of Original Certificate of Title No. 2889 and the issuance of a new title in Aurelia's name under Section 112 of Act No. 496.

4. Court Order
   The court granted the petition on August 10, 1951, ordering the cancellation of the original certificate and the issuance of a new one in Aurelia's name, subject to the usufructuary right of Hermenegilda Tan and claims under Section 4, Rule 74 of the Rules of Court.

5. Intervention of Geronimo Miraflor
   On September 10, 1951, Geronimo Miraflor filed a motion, asserting that Antero Miraflor was survived by his grandmother, Catalina del Fierro, who should inherit his share. Catalina had allegedly sold her share to Geronimo in 1946. Geronimo claimed that neither he nor Catalina was notified of the petition, and he sought reconsideration of the court's order.

6. Denial of Motion
   The court denied Geronimo's motion on September 21, 1951, stating that the issue raised could not be resolved in the registration case and that Geronimo should file a separate action to protect his rights.

7. Certiorari Petition
   Geronimo filed a petition for certiorari, arguing that the court lacked jurisdiction due to the absence of notice to all interested parties and publication as required by law. The case was certified to the Supreme Court by the Court of Appeals.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction and Notice Requirements
   The Court emphasized that jurisdiction in land registration cases requires notice to all parties whose interests might be affected. The failure to notify Geronimo Miraflor and Catalina del Fierro rendered the court's order void for lack of jurisdiction.

2. Inapplicability of Summary Procedure
   Section 112 of Act No. 496 provides a summary procedure for non-controversial matters, such as transferring title from a deceased owner to their heirs when there is no dispute. However, in this case, a substantial controversy existed over the inheritance of Antero Miraflor's share, making the summary procedure inadequate. The proper remedy was an ordinary civil action.

3. Protection of Rights
   The Court upheld the principle that parties with legitimate claims must be given the opportunity to assert their rights in a proper judicial proceeding. The denial of Geronimo's motion for reconsideration was justified because the issue could not be resolved summarily in the registration case.