Case Summary (G.R. No. L-4205)
Application for Land Registration
Cabanas filed an application for the registration of his property with the Court of Land Registration under the Land Registration Act. Details regarding the acquisition, boundaries, and title deeds of the property were included in his application. The Attorney-General entered an appearance for the Director of Lands but did not register any formal opposition to Cabanas's claim during the preliminary stages of the case.
Court Proceedings and Initial Judgment
On June 28, 1907, the court issued a judgment favoring Cabanas, granting him the registration of the property. However, the Attorney-General objected to the portion of the decision that granted registration based on adverse possession under section 54, paragraph 6, of Act No. 926, indicating an intention to appeal the decision on grounds that the evidence did not support the court’s ruling.
Legal Basis for Respondent's Appeal
Despite the objection by the Attorney-General, Cabanas contended that the appeal was inadmissible. This argument rested on the fact that the Director of Lands had neither answered nor opposed the application, effectively admitting the allegations made by Cabanas as per section 94 of the Code of Civil Procedure. This section dictates that failure to provide a written answer or opposition to the application results in the admission of all allegations.
Default and Rights of Parties
The relevant statutes, including sections 35 and 36 of Act No. 496, outline the protocol for situations where no party appears to contest an application. Given that the government was included in the general default ordered by the court, the absence of opposition rendered the original claims as accepted. Thus, the court’s decision affirming Cabanas's right to the property adhered to the stipulated legal processes.
Lack of Standing for Appeal
The appeal taken by the Attorney-General was predicated on a supposed injury; however, since no claim for possession was made by the government and no opposition was lodged against Cabanas's application, it was determined that the Director of Lands had no legal standing to appeal. The relevant doctrine from prior cases
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Background of the Case
- Julian Cabanas, a widower residing in San Isidro del Canipo, Leyte, filed an application for land registration, claiming absolute ownership of a rural property.
- The property in question spans an area of 18,741,675.20 square meters, assessed at $3,404, United States currency, and is occupied by Cabanas and his laborers.
- Accompanying the application were title deeds detailing the acquisition, boundaries, and a plan of the property.
- The proceedings began with service upon the Director of Lands, represented by the Attorney-General.
Filing and Amendments
- On November 15, the petitioner requested to amend his application, seeking registration under Act No. 926 should his primary petition fail.
- The record indicated no opposition or answer from the Attorney-General regarding the application for registration based on dominion.
Court Proceedings and Decision
- The Court of Land Registration, after examining oral and documentary evidence, ruled on June 28, 1907, in favor of Cabanas, granting property registration.
- The Attorney-General, on behalf of the Director of Lands, filed an exception to t