Case Summary (G.R. No. L-18150)
Background of the Case
On January 7, 1957, the spouses Bruno Papa and Valentina Agaceta filed an application to register a parcel of land under Act 496. Following the required publication of the application, a hearing was scheduled for May 16, 1957, during which an order of general default was issued. However, Baldomero Baldoz, the father of the appellant, filed a petition to lift this order and attached his opposition to the application. The court, on the same date, granted this petition, resetting the case for hearing on October 1, 1958.
Procedural Developments
Prior to the rescheduled hearing, Baldomero Baldoz passed away on July 28, 1957. The appellant, Superior Baldoz, did not inform the court of his father's death, leading to the hearing notice being returned unserved. On September 11, 1958, the appellees substituted the original applicants, and at the October 1 hearing, only the appellees attended, resulting in Baldomero's default due to non-appearance. Following this, the court allowed the appellees to present their evidence and subsequently issued a judgment for the registration of the land in their favor on February 16, 1959.
Enforcement of Judgment and Motion for Demolition
After the judgment became executory, the Land Registration Commission issued Decree No. N-71779, and Original Certificate of Title No. 15264 was subsequently issued in the names of the appellees. On June 17, 1959, the appellees filed a "Motion for Issuance of Writ of Demolition" and "Motion for Issuance of Writ of Possession." The appellant filed an opposition and a counter-petition to stay the judgment's effects, which was denied on February 9, 1960.
Annulment Action Commencement
On March 1, 1960, the appellant initiated an action in the Court of First Instance of Pangasinan for the annulment of the registration decision on two grounds: (1) the court's reversible error in declaring his father in default despite his previously filed opposition, and (2) the denial of his motion for substitution deprived him of his day in court. The appellees sought to dismiss the complaint, asserting that the appellant lacked legal standing, that the complaint did not state a cause of action, and that the claim was barred by res judicata and the statute of limitations.
Court Rulings and Res Judicata Doctrine
On September 30, 1960, the court dismissed the complaint, emphasizing that the final judgment in Registration Case No. 2215 constituted res judicata for the present action, and noting that the annulment action filed more than a year after the decree's issuance could not proceed as it lacked grounds of fraud as specified in Section 38 of Act 496. The appellant contended that the lower court had lost jurisdiction over his deceased father; however, the court found
...continue readingCase Syllabus (G.R. No. L-18150)
Case Background
- The case originated from an application for land registration under Act 496, filed on January 7, 1957, by spouses Bruno Papa and Valentina Agaceta for a parcel of land identified as Psu-59688, covering an area of 37,671 square meters in Pangasinan.
- The application underwent the necessary publication process in the Official Gazette and was set for hearing on May 16, 1957.
- An order of general default was entered during the initial hearing.
Procedural Developments
- On the same day of the default order, Baldomero Baldoz, father of the appellant Superior Baldoz, filed a petition to lift the order of default and submitted an opposition to the application.
- The court granted this petition and rescheduled the hearing for October 1, 1958.
- Baldomero Baldoz died on July 28, 1957, but Superior Baldoz did not notify the court of his father’s death, resulting in the notice of the October 1 hearing being sent to the deceased.
- The appellees were permitted to substitute the original applicants before the scheduled hearing.
Hearing and Default Judgment
- At the hearing on October 1, 1958, no oppositor appeared since the notice had not reached Baldomero Baldoz.
- The court allowed the appellees to present evidence supporting their application and declared Baldomero Baldoz in default due to non-appearance.
- On October 10, 1958, a motion was filed by Baldomero Baldoz’s counsel to set aside the default order, citing the reason of his death and requesting the substitution of appellant Superi