G.R. No. 157719 - Republic vs. Tapay

In 1980, respondents Flora Tapay (deceased) and Clemente Tapay filed an application before the Regional Trial Court (RTC) of Lipa City for the registration of Lot No. 10786, covering an area of 684 square meters.
The respondents based their claim on historical possession, alleging that Francisca Cueto had occupied the property since 1925 and that the land later passed to Teofila Lindog, from whom the respondents inherited the property upon Teofila’s intestate demise in 1971.

The Republic, represented by the Office of the Solicitor General (OSG), opposed the application for registration, arguing:

The documents submitted by respondents (muniments of title, tax declaration, and tax receipts) were not competent evidence to establish ownership.
The respondents’ open, continuous, exclusive, and notorious possession did not equate to ownership under the legal concept.
The right to claim ownership based on a Spanish title or grant was forfeited since the respondents did not file the appropriate application within the time stipulated by Presidential Decree No. 892.
The parcel in question was part of the public domain.

A notice of the application was duly posted, published, and served on the adjoining property owners, and the RTC subsequently issued an order of general default “against the whole world.”

During the registration proceedings, the Land Registration Commission (LRC, now known as the Land Registration Authority or LRA) issued a report indicating that, based on the Books of Cadastral Lots, the subject lot had been previously registered in another case (Cadastral Case No. 33, LRC (GLRO) Cadastral Record No. 1305).
The LRC also reported that the previous adjudication had been rendered to another person; however, the court was unable to establish the identity of that person due to the unavailability of complete records, including the decision in the cadastral case.
Despite the LRC’s report, the RTC, in its May 28, 1982 Decision, adjudicated the land in favor of the respondents, thereby ordering that once the decision became final the Land Registration Commission should issue the decree of registration and corresponding certificate of title.

When the RTC directed the LRC to execute the decree of registration, the LRC instead submitted a supplemental report reiterating the previous registration proceedings in Cadastral Case No. 33.
Based on the LRC’s report and acknowledging the lack of clear evidentiary records, the RTC issued an August 14, 1996 Order setting aside the decision in the cadastral case to give effect to its own May 28, 1982 Decision.

Petitioner (the Republic) appealed, contending that the RTC did not have the authority to nullify the decision of a co-equal court—that is, the decision arising from the cadastral case.
The CA, while generally recognizing that an RTC lacks power to interfere with a decision of a co-equal court, found that:

The petitioner had failed to produce the records of the cadastral proceedings.
The LRC admitted its inability to determine the identity of the person allegedly awarded the property in the cadastral case.
The recommendation by the LRC to nullify the cadastral decision indicated that the decision had not attained necessary finality.

The CA noted that, except for the Republic, no other party had asserted any claim to the property.
Based on these findings, the CA affirmed the RTC’s August 14, 1996 Order, effectively allowing the registration proceedings to continue in favor of the respondents.

Whether the RTC had the authority to nullify the decision of the cadastral court, a co-equal court, and whether such nullification was proper under the doctrine of judicial stability.

Whether the evidence regarding the existence and finality of the alleged decision in Cadastral Case No. 33 was sufficient to bar the respondents from obtaining a registration decree.

Whether the doctrine of res judicata — and specifically the immutability of judgments — precluded the RTC’s decision to set aside the cadastral proceedings and thereby affect the respondents’ application for registration.