Case Summary (G.R. No. 66344)
Background of the Case
On October 1, 1940, the Court of First Instance of Davao, presided over by Judge Enrique Fernandez, adjudicated Lot No. 384 in favor of Constancio Guzman. The decision acknowledged title claims of other parties without definitively resolving the ownership of certain agricultural improvements on the lot. Following World War II, documentation related to the case was lost, impeding further legal proceedings. In 1967, Original Certificate of Title No. Q-217 was issued to Guzman by the Land Registration Commission.
Petition for Review
The Lanzonas, claiming to have acquired rights to the property from Constancio Bolcan in 1942 and asserting more than twenty-five years of possession, filed a petition for review citing fraud in the issuance of the registration decree. Emilio Alvarez, as successor-in-interest to Guzman, contested this assertion, arguing that the 1940 decision had become final and executory.
Appellate Court's Ruling
In its decision on June 10, 1982, the Intermediate Appellate Court found that the trial court had erred by ruling in favor of the petitioners. The appellate court declared the decree of registration valid and affirmed the issuance of the original title, dismissing the petition for lack of merit and stating that no fraud had occurred in the issuance process.
Supreme Court's Findings on Fraud
The Supreme Court, upon review, determined that the question of fraud was a factual matter that could not be reassessed under Rule 45. The appellate court’s conclusion that no fraud existed in Judge Fernandez's original decision was upheld, despite concerns over the lack of a certified true copy of the referenced Supreme Court decision. The appellate court's evaluation that such a lack does not automatically imply fraud was deemed correct.
Finality of the 1940 Decision
The Supreme Court concurred with the appellate court’s findings regarding the finality of the 1940 decision. It noted that the appellants had failed to substantiate their claims regarding the appeal made to the higher court, and the destruction of records during the war did not invalidate the decision. The court emphasized the responsibility of the appellant to initiate reconstitution of the appeal records, which was not carried out, thereby leading to the conclusion that the decision must stand as final.
Acquisitive Prescription and Factual Iss
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Case Citation
- G.R. No. 66344
- Decision Date: July 02, 1990
- Jurisprudence: 265 Phil. 36
- Division: First Division
Parties Involved
- Petitioners: Miguel Lanzona (Deceased) and Iluminada E. Lanzona
- Respondents: Hon. Intermediate Appellate Court and Emilio Alvarez
Procedural Background
- This case is a petition for review concerning a decision made by the Intermediate Appellate Court (now the Court of Appeals) dated June 16, 1982, in CA-G.R. No. 52469-R.
- The case centers around a reversal of an order dated August 26, 1972, from the Court of First Instance of Davao regarding Cadastral Case No. 1, G.L.R.O. Cad. Rec. No. 317 for Lot No. 384.
Factual Background
- On October 1, 1940, Judge Enrique Fernandez of the Court of First Instance of Davao adjudicated Lot No. 384 to Constancio Guzman, referencing a previous Supreme Court decision that did not address the ownership of crops on the land.
- The prior decision acknowledged the rights of Ines Labarca and Constancio Bolcan to certain crops on Lot 384.
- The records of the case were destroyed during World War II, and the earlier decision was never reconstituted.
- A decree of registration and Original Certificate of Title No. Q-217 were issued in favor of Guzman on December 15, 1967.
- Petitioners Lanzona claimed to