Title
Philippine Manufacturing Co. vs. Imperial
Case
G.R. No. 24599
Decision Date
Sep 15, 1925
The Supreme Court ruled that the petitioner should have appealed the lower court's decision instead of filing an original petition, as the unnotified land award was not subject to direct Supreme Court intervention.
Font Size

Case Digest (G.R. No. 24599)

Facts:

  • The case involves the Philippine Manufacturing Co. (petitioner) against Judge Carlos A. Imperial and the heirs of Tomas Cabangis.
  • On July 20, 1912, Tomas Cabangis sold land at Manila Bay to the Manila Refining Co., which later transferred it to the Philippine Manufacturing Co.
  • The petitioner sought to register the land, resulting in Transfer Certificate of Title No. 3936.
  • On February 11, 1922, the Director of Lands initiated a cadastral proceeding for ownership determination in Tondo, Manila, including the petitioner's registered land.
  • A general default for unclaimed lots was entered on January 16, 1928, with lots 31, 32, and 35 adjudicated to the petitioner.
  • Concerns arose regarding the foreshore status of part of lot 35, prompting the petitioner to lease the disputed area from the government.
  • On March 19, 1925, the Cabangis heirs claimed ownership of lot 39, a subdivision of lot 35, during the cadastral proceeding.
  • The court awarded lot 39 to the Cabangis heirs on June 18, 1925, based on their long possession.
  • The petitioner was unaware of the proceedings regarding lot 35 and learned of the decision on June 26, 1925.
  • The petitioner filed a motion to set aside the court's decision on July 17, 1925, which was denied on July 21, 1925.
  • The petitioner then sought relief under Section 513 of the Code of Civil Procedure.

Issue:

  • (Unlock)

Ruling:

  • The court ruled that the case was suitable for relief under Section 113 of the Code of Civil Procedure.
  • The court determined that the July 21, 1925 order from the lower court was appealable.
  • The court concluded that t...(Unlock)

Ratio:

  • The court reasoned that the petitioner, holding a Torrens title for the entire lot 35, was not required to formally claim the property in the cadastral proceeding.
  • The court had a duty to respect the existing title, and the lack of notification regarding the hearings constituted surprise and excusable neglect.
  • The proceedings against the pet...continue reading

Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.

© 2024 Jur.ph. All rights reserved.