Facts:

The case involves the Republic of the Philippines and the Director of Lands as petitioners against Hon. Numeriano G. Estenzo, the Judge of the Court of First Instance of Leyte, Branch V, Ormoc City, and private respondents Felipe Adolfo and Francisca Padilla, spouses. The dispute centers on the ownership of a parcel of land located in Barrio Valencia, Ormoc City. The petitioners assert that the land in question is public land, as established by a decision from the Cadastral Court on October 31, 1940, which declared Lot No. 8423 of the Ormoc Cadastre as public land. In contrast, the private respondents claim ownership based on their purchase of the land from the original claimant, Apolonia Parrilla, and a subsequent adjudication in their favor in 1972. The spouses filed a petition on January 12, 1972, seeking to reopen the 1940 decision under Republic Act No. 931, as amended. They argued that they had purchased the land in 1948 and had been in open, continuous, peaceful, and a...

Facts:

1. Cadastral Court Decision (1940):
   On October 31, 1940, the Cadastral Court declared Lot No. 8423 of the Ormoc Cadastre as public land.

2. Private Respondents' Claim (1972):
   On January 12, 1972, Felipe Adolfo and Francisca Padilla (the SPOUSES) filed a petition to re-open the 1940 cadastral decision under Rep. Act No. 931, as amended. They claimed ownership of Lot No. 8423, having purchased it in 1948 from the original claimant, Apolonia Parrilla. They argued that the land was declared public land due to excusable negligence, accident, or mistake. They also asserted that they and their predecessor-in-interest had been in open, continuous, peaceful, and adverse possession of the land, which had not been alienated, reserved, leased, or disposed of by the government.

3. Lower Court Decision (1972):
   Despite opposition from the Director of Lands, the respondent Judge granted the SPOUSES' petition on May 9, 1972, adjudicating Lot No. 8423 in their favor.

4. Petitioners' Appeal:
   The Republic of the Philippines and the Director of Lands appealed the decision, arguing that the lower court lacked jurisdiction to re-open the cadastral proceedings because the period for re-opening under Rep. Act No. 931 had expired on December 31, 1968.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction and Expiration of Period:
   The Court held that the period for re-opening cadastral proceedings under Rep. Act No. 931 expired on June 20, 1958, and was extended only until December 31, 1968, by Rep. Act No. 2061. Since the SPOUSES filed their petition in 1972, more than three years after the expiration of the reglementary period, the lower court had no jurisdiction to entertain the petition.

2. Nature of the Action:
   The Court emphasized that the nature of an action is determined by the facts alleged in the complaint. The SPOUSES' petition was premised on Rep. Act No. 931, not on confirmation of imperfect title. The allegations in their petition conformed to the conditions required under Rep. Act No. 931, not those for confirmation of imperfect title.

3. Rep. Act No. 6236:
   The Court clarified that Rep. Act No. 6236, which extended the time limit for filing applications for free patents and judicial confirmation of imperfect titles, did not apply to the re-opening of cadastral proceedings. The law explicitly excluded re-opening of cadastral cases, as evidenced by its silence on the matter compared to Rep. Act No. 2061, which included such provisions.

4. Timeliness of Appeal:
   The Court noted that the petitioners' appeal was timely filed within the 30-day period prescribed by the Rules of Court.

The decision is immediately executory.