G.R. No. 100831 - Reliance Commodities, Inc. vs. Daewoo Industrial Co., Ltd.

The case involves an appeal from a Court of First Instance order and resolution dated October 29 and 30, 1936, respectively.
The applicants—Municipal Council of San Pedro, Laguna, and others—filed a petition for escheat claiming ownership of the Hacienda de San Pedro Tunasan under sections 750 and 751 of the Code of Civil Procedure.
The petition was brought on behalf of the municipality, asserting that it was entitled to the hacienda due to the absence of legal heirs and the resultant escheat of the property.

Municipal Council of San Pedro and affiliated representatives.
Filed a petition for escheat, alleging that the hacienda had become state property upon the death of its (intestate) owner without heirs.

Colegio de San Jose, Inc. appeared specially, contending that the court lacked jurisdiction and that the petition was factually insufficient to warrant the remedy.
Carlos Young intervened, arguing that the petition was improperly docketed and that the Code of Civil Procedure under which it was filed was not applicable given the date of the original owner's death (April 15, 15U6).
Both oppositors sought the dismissal of the escheat petition, asserting respective interests in the Hacienda de San Pedro Tunasan—ownership by the Colegio and a leasehold interest by Carlos Young.

The petition alleged that the deceased died intestate, leaving behind real and/or personal property without any heir or person by law entitled to claim it.
It was asserted that the municipality, being the last known residence of the deceased, was entitled to pursue escheat as a special proceeding under sections 750 and 751 of the Code of Civil Procedure.

The petition recited historical events where the temporal properties of the Jesuits—including the Hacienda de San Pedro Tunasan—were confiscated by order of the King of Spain and transferred to the Crown.
It further alleged that through transfers following the Spanish-American war and the Treaty of Paris (December 10, 1898), the property eventually came under the control of the United States.
Subsequent legislative actions, including the Act of the U.S. Congress of July 1, 1902, and the Tydings-McDuffie Law of March 24, 1934, led to the property being ceded to the Commonwealth of the Philippines on November 15, 1935.

On October 29, 1936, the lower court overruled the objection regarding the appearance and intervention of Colegio de San Jose and Carlos Young.
On October 30, 1936, the court resolved to dismiss the petition for escheat, ordering costs to be paid by the petitioners.
The petitioners raised several assignments of error, including:

The improper intervention of oppositors in the case.
The dismissal of the petition without affording them an opportunity to amend.
The judicial notice of facts from other judicial records used to bolster the lower court’s resolution.
The contention that the municipality of San Pedro neither had standing to petition for escheat nor did the petition state sufficient facts justifying the remedy.
The imposition of costs even in the absence of a full trial.

Whether the objection to the appearance and intervention of Colegio de San Jose, Inc. and Carlos Young should have been sustained, or if they were proper parties given their alleged interests in the Hacienda.
Whether the petition for escheat, based on sections 750 and 751 of the Code of Civil Procedure, sufficiently alleged the necessary facts to give the Court of First Instance jurisdiction.
Whether the filing of a motion to dismiss (functioning as a demurrer) in a special proceeding for escheat is procedurally acceptable, even if not explicitly provided for under ordinary pleadings.
Whether the lower court erred in taking judicial notice of facts from another civil case pending in the same court, thereby potentially distorting the factual matrix of the present case.
Whether the municipality of San Pedro possessed the legal standing to initiate the petition for escheat, considering the historical and legal status of the Hacienda de San Pedro Tunasan.
Whether the dismissal of the petition without affording the petitioners an opportunity to amend violates the principles of due process, and if the imposition of costs was justified under the provisions of the Code of Civil Procedure.