G.R. No. 49065 - Vda. de Centenera vs. Sotto

On June 20, 1940, Mariano Garchitorena filed a motion praying for the approval of subdivision plan Psu-66063-Amd. and the issuance of certificates of title in his name on specific lots.
The motion sought titles for lots 2, 3, and 4 of the original plan Psu-66063 and for lots 1, 5, 6, 7, and 8 of the amended subdivision plan.
The motion was based on earlier judicial determinations and transactions that included conflicting claims and interests between family members and third parties.

On May 14, 1931, a lower court rendered a decision awarding Rita Garchitorena, as the heiress of her father Andres, title over four lots subject to certain liens and exclusions (including lands belonging to Ramon and Jose Alvarez, portions of public domain, and lands related to other claimants).
This judgment was modified by the Supreme Court, and subsequent steps were taken, leading to the adjudication of lots 1, 2, 3, and 4 to Mariano Garchitorena in consideration of a payment of P28,745.93.
A deed of sale was executed on September 8, 1935, which was approved on April 26, 1940, and on April 27, 1939, Mariano Garchitorena purchased the disputed 500 hectares adjudicated to Ramon and Jose Alvarez.

Sought registration of titles for several lots affected by previous judicial decisions and transactions.
Emphasized payment and acquisition as proof of his substantive title over the contested parcels.

H. P. Obias – Contended that the exclusion in lot number 1, originally measured as 300 hectares, should in fact cover 961 hectares, and argued that awarding title on some lots (belonging originally to Ramon and Jose Alvarez) to Mariano would be erroneous.
Ana Pataan – Challenged the lower court’s nullification of her free patent title No. 1406, arguing that the land covered by it (10 hectares) was part of a larger tract declared private property before its issuance.
Vicente Sotto – Asserts that he acquired title through a sheriff’s sale resulting from a judgment ordering Rita Garchitorena to pay him P960.84, and contended that he should not suffer prejudicial effects from judgments in other related cases.

The lower court, in its order dated June 28, 1941, decreed the issuance of certificates of title for certain lots in favor of Mariano Garchitorena, based on the amendments and modifications of previous judgments.
The proceedings involved important statutory references such as Section 38 of the Land Registration Act No. 496 as amended by Act No. 3621.
The decision was built on the evidentiary record showing that both the original application for land registration and subsequent judicial determinations had fully settled the rights of the various parties involved, including the liquidation of Andres Garchitorena’s estate.

Ordering the issuance of certificates of title in favor of Mariano Garchitorena for the lots in controversy despite the oppositions of H. P. Obias, Ana Pataan, and Vicente Sotto.
Extending registration to lots originally adjudicated to heirs of Andres Garchitorena (e.g., Rita Garchitorena) when subsequent transactions (including payment and public auction proceedings) had taken place.

H. P. Obias’ argument regarding the proper measurement and exclusion of public domain lands and the erroneous awarding of lots originally associated with Ramon and Jose Alvarez.
Ana Pataan’s claim that her free patent title should not have been declared null and void because she was not properly mentioned in the original application despite her connection via her husband’s role.
Vicente Sotto’s contention that his sheriff’s sale and subsequent registration should protect his right to the land, notwithstanding the judgment involving Rita Garchitorena and related proceedings.

Whether the application of the registration procedures under Act No. 496, as amended, was properly followed, particularly regarding:

The requirement that an oppositor must explicitly “apply for the remedy desired” as a condition precedent for a positive decree of registration.
The effect of a notice of lis pendens and the impact of prior judgements in regulating subsequent transactions and claims.