Title
Republic vs. Heirs of Tiotioen
Case
G.R. No. 167215
Decision Date
Oct 8, 2008
The Supreme Court grants the petitioner's appeal in the land registration dispute, allowing the case to proceed despite procedural defects and lapses, emphasizing the importance of the issues involved and the need to prevent a grave injustice.
Font Size

Case Digest (G.R. No. 167215)

Facts:

  • The case "Republic v. Heirs of Tiotioen" involves a land registration dispute over two parcels of land in Pico, La Trinidad, Benguet, totaling 180,488 square meters.
  • Evaristo Tiotioen initially applied for judicial confirmation and registration of the land under the Torrens System on September 6, 1993.
  • After Evaristo's death on June 21, 1997, his heirs continued the application process.
  • Opposition came from Santiago A. Santiago, the Municipality of La Trinidad, Benguet, and the Republic of the Philippines, represented by the Department of Environment and Natural Resources (DENR) and the Office of the Solicitor General (OSG).
  • The OSG formally entered its appearance on October 20, 1994, and authorized the Provincial Prosecutor of Benguet to represent the case.
  • The opposition argued that the land was part of the communal forest of La Trinidad and thus inalienable public domain land.
  • Despite objections, the Regional Trial Court (RTC) of La Trinidad, Branch 63, granted the application on August 30, 2001, confirming the heirs' ownership.
  • Notices of the decision were received by the petitioner and the municipality on September 6 and 7, 2001, respectively.
  • The municipality filed a timely motion for reconsideration, which the petitioner belatedly adopted on October 5, 2001.
  • The RTC denied the motion for reconsideration on December 6, 2001, and the OSG was informed of this denial only on January 4, 2002.
  • The OSG filed a notice of appeal on January 11, 2002, which the RTC denied as untimely.
  • The Court of Appeals (CA) granted the municipality's appeal but denied the petitioner's appeal, leading to the present petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petitioner's appeal, allowing the notice of appeal filed on January 11, 2002, to be given due course.
  • The procedural lapses were set aside to prevent a gra...(Unlock)

Ratio:

  • The Supreme Court emphasized that the belated filing of an appeal by the State, or even its failure to file an opposition, does not strip the government of its right to appeal from a judgment.
  • The Court referenced precedents where procedural lapses were excused to avert grave injustice and to ensure the...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.