Case Summary (G.R. No. 175023)
Overview of Proceedings
This petition for certiorari seeks to annul the Order of the Court of First Instance of Rizal that denied the Motion to Admit Petition to Reopen Proceedings. The original disputes relate to Free Patents awarded to respondents Eusebio and Lara for parcels of land later found to be underwater, leading to further actions from the Director of Lands to have these patents cancelled due to non-compliance and fraudulent procurement.
Initial Application and Discovery
In 1956, respondents Lara and Eusebio filed Free Patent Applications for land they subsequently received titles for. An investigation by the Anti-Graft and Corruption Board revealed that the land was submerged in Laguna de Bay, and no improvements had been made. Subsequently, the respondents admitted, through affidavits, that they had not met the requirements of the Public Land Act and agreed to surrender their titles.
Cancellation of Patents
The Director of Lands filed complaints for the cancellation of these patents after the affidavits were submitted. Despite proper service of summons, the respondents failed to respond, leading to a default judgment in favor of the Director of Lands, which annulled the patents. This judgment was not contested, rendering it final and executory.
Subsequent Case Filed by Respondents
In 1967, almost five years later, respondents Eusebio and Lara attempted to annul the earlier decisions via Civil Case No. 10047, claiming lack of jurisdiction and fraud. However, the court erroneously granted their motion, and subsequent decisions set aside the earlier annulments, reinstating the patents.
Motion to Reopen Proceedings
The Director of Lands later filed a motion to reopen proceedings, arguing jurisdictional issues and citing ongoing fraudulent transactions related to the disputed land parcels. However, the subsequent court order denied this motion, leading the petitioners to seek relief through certiorari.
Findings on Jurisdiction
The Supreme Court concluded that the lower court had, in fact, acquired jurisdiction over the respondents, who were properly served with summons. The notion that they were unaware of the prior proceedings did not hold, as detailed evidence proved otherwise. The Final Judgment in Civil Cases Nos. 6747 and 6748 should remain untouchable under the principles of res judicata, effectively precluding rehearing.
Examination of Good Faith Acquisitions
The Court determined that mere allegations of good faith by subsequent buyers Gil Venzuela, Rodolfo Cenidoza, and the spouses Orosa could not protect them under the law. The properties in question involved non-disposable land
...continue readingCase Syllabus (G.R. No. 175023)
Introduction
- This case involves a petition for certiorari with a preliminary injunction filed by the Republic of the Philippines, represented by the Director of Lands, against the Hon. Andres Reyes, a judge of the Court of First Instance of Rizal, and other respondents.
- The petition seeks to annul an order issued by the Court of First Instance of Rizal on December 16, 1968, which set aside previous orders and denied a motion to admit a petition to reopen proceedings.
Background
- Respondents Urbano C. Lara and Godofredo R. Eusebio filed Free Patent Applications for two parcels of land on April 17, 1956.
- These applications were approved on June 14, 1956, leading to the issuance of Free Patent Nos. V-45853 and V-45854, which were registered as Original Certificates of Title Nos. 140 and 139.
- Subsequent investigations revealed that the lands were submerged and part of Laguna de Bay, with no signs of occupation or cultivation by the respondents.
Prior Proceedings and Findings
- On March 16 and March 22, 1960, Eusebio and Lara admitted non-compliance with the Public Land Act and agreed to have their patents canceled.
- The Director of Lands filed complaints for cancellation of the patents and titles, resulting in decisions that nullified the patents and titles on October 6, 1962, which became final due to the respondents