G.R. No. L-30859 - Vda. de Cailles vs. Mayuga

The dispute centers on the ownership of a parcel of land located in Barrio Almanza, Las Piñas, Rizal, known as Lot 9 of Plan Psu-11411 Amd-2 (as per the records of the Bureau of Lands).
The underlying issue involves registration proceedings initiated in 1937 in the Court of First Instance of Rizal, where a decision was rendered in favor of Estanislao Mayuga as the registered owner.
The original registration record was destroyed by fire during the Japanese Occupation, necessitating the reliance on secondary evidence to establish its contents.

Maria Mayuga Vda. de Cailles and the heirs of Narciso, Angel, Nestor, and Maura Mayuga, who asserted their claim that the land belonged pro indiviso to the heirs of Narciso Mayuga.
They argued that Dominador Mayuga had been expressly disinherited in the will of Estanislao Mayuga and that the land was never rightfully his.

Dominador Mayuga, who initiated the petition for a registration decree on the basis of being the only son and forced heir of Estanislao Mayuga.
Subsequent transfers of rights were effected: Dominador transferred his rights via a deed of sale to Marciano Villanueva, who then conveyed the land to Nicolas Y. Orosa.

Constantino Factor, surviving spouse of Maura Mayuga, joined as one of the oppositors.
Tomas B. Aguirre and Philippine Shares Corporation later sought leave to intervene due to overlapping interests concerning adjoining properties.

The registration proceedings began with Estanislao Mayuga’s application for title registration, which was docketed as Land Registration Case No. 1278 and set for a hearing on May 6, 1937.
Notice of the hearing was duly published in the Official Gazette, thereby providing constructive notice to interested parties.
Secondary evidence was introduced to establish the existence and content of the decision rendered on May 6, 1937; this evidence included:

Documentary fragments and certifications from the Land Registration Commission and the Director of Lands.
Annotations on the blueprint (Psu-11411-Amd-2) evidencing that it had been "AMENDED IN ACCORDANCE WITH THE DECISION OF THE COURT OF FIRST INSTANCE OF RIZAL."
Testimonies, notably from Atty. Marcelo M. Bobadilla, affirming that the registration case was unopposed and resulted in a final decision.

The evidence also documented subsequent land surveys, subdivision of Lot 9, tax declarations in the name of Dominador Mayuga, and recorded deeds of sale that transferred the property ultimately to Nicolas Y. Orosa.

The Trial Court, in its decision dated January 29, 1962, found that the secondary evidence was sufficient to establish the decision of May 6, 1937, thereby awarding the title to Estanislao Mayuga and, by extension, to his heir Dominador Mayuga and his transferees.
On appeal, the Court of Appeals affirmed the Trial Court’s findings, aligning with its conclusion that the secondary evidence was reliable and complete.
Petitioners later appealed, contending that:

The secondary evidence was insufficient to prove the existence and key contents of the lost registration record.
Their own documentary evidence, which purported to support the land's incorporation into Narciso Mayuga’s estate, was improperly disregarded.
They had not lost their rights by prescription despite the long lapse of time resulting from unopposed registration proceedings.

The motion for intervention by Tomas B. Aguirre and Philippine Shares Corporation was raised, arguing an interest in resolving overlapping property concerns, although this motion was eventually denied.

The destruction of court records during the enemy occupation was confirmed by certifications from both the Clerk of Court and the Director of Lands.
The registration proceedings evidenced by secondary documentation included detailed records of land surveys, amendments to the plan, official notices, and tax declarations, forming a coherent narrative that substantiated the existence of the 1937 decision.
The legal transactions following the registration decision (sales and transfers) reinforced the chain of title ultimately favoring the respondents.

Whether the secondary evidence presented by the respondents was sufficient and admissible to establish the existence and contents of the original registration record that was destroyed during the Japanese Occupation.
Whether the trial court’s determination—affirmed by the Court of Appeals—that the evidence conclusively established the ownership of Lot 9 by virtue of the May 6, 1937 decision was correct.
Whether the petitioners’ claims that Dominador Mayuga was disinherited and that the property belonged to the heirs of Narciso Mayuga were properly considered or should have been given greater weight.
Whether the petitioners’ failure to timely contest the registration proceedings, resulting in a lapse of over ten years, precluded any legitimate challenge to the established title.
Whether the intervention of Tomas B. Aguirre and Philippine Shares Corporation, predicated on overlapping interests with adjacent properties, should have affected or been allowed in the proceedings.