Case Summary (G.R. No. 238338)
Relevant Dates and Procedural Milestones
- Circa 1925–1971: Alleged continuous possession by predecessors (Francisca Cueto to Teofila Lindog; Teofila died intestate in 1971).
- 1980: Respondents filed application for registration of Lot No. 10786 before the RTC of Lipa City.
- May 28, 1982: RTC (Branch 12, Lipa City) issued decision adjudicating the land to applicants (respondents) and directing issuance of a decree of registration once decision became final.
- August 14, 1996: RTC granted respondents’ motion to set aside a decision in Cadastral Case No. 33 (LRC (GLRO) Cadastral Record No. 1305) that the LRC reported as having previously adjudicated the same lot.
- March 20, 2003: Court of Appeals affirmed the RTC’s August 14, 1996 Order.
- March 2, 2022: Supreme Court decision denying the petition for review and affirming the CA.
Applicable Law and Doctrines Identified
- 1987 Constitution (governing framework due to decision date).
- Presidential Decree No. 892 (discontinuance of Spanish mortgage system and limitation on use of Spanish titles in land registration proceedings) — raised by petitioner.
- Presidential Decree No. 1529, Section 31(2) (referenced regarding effect of decree of registration).
- Doctrines applied or discussed: doctrine of judicial stability (noninterference by co-equal courts), res judicata, immutability of judgment; principles and purpose of land registration (to finally settle title and quiet ownership).
Factual Background and Grounds of Opposition
Respondents traced title to possession beginning in 1925 through a chain culminating in Teofila Lindog; respondents inherited upon her intestacy. The Republic, through the OSG, opposed the registration application on multiple grounds: (1) the documentary and possession evidence submitted (muniments of title, tax declarations, tax receipts, occupation) were not competent proof of acquisition; (2) possession in the concept of an owner was insufficient; (3) respondents could no longer rely on any Spanish title/grant because of PD No. 892 and failure to comply with required applications; and (4) the parcel formed part of the public domain.
RTC Proceedings and May 28, 1982 Decision
The RTC proper served, published, and posted notice of the registration application and entered an order of general default against the whole world. Despite an LRC report indicating that Lot No. 10786 had previously been the subject of registration proceedings in Cadastral Case No. 33 and had allegedly been adjudicated to another person, the RTC adjudicated the land to respondents on May 28, 1982, decreeing them true and absolute owners in equal shares and directing that, once the decision became final, a decree of registration be issued.
LRC Report and the Alleged Cadastral Case No. 33
The LRC reported that the lot had been the subject of a prior registration matter (Cadastral Case No. 33, LRC (GLRO) Cadastral Record No. 1305) and that the cadastral court had allegedly adjudicated the lot to another person. However, the LRC could not produce the records of that cadastral case, including a copy of the purported decision, and thus could not identify the party adjudicated. The LRC later recommended nullification of the cadastral-court decision so that it could issue a decree of registration in favor of respondents.
RTC’s August 14, 1996 Order
Respondents filed a motion to set aside the decision in Cadastral Case No. 33 to give effect to the RTC’s May 28, 1982 Decision. The RTC granted that motion on August 14, 1996, setting aside the decision in Cadastral Case No. 33 as prayed for by respondents. The trial court’s action effectively eliminated the asserted obstacle to issuing a registration decree in favor of respondents.
Court of Appeals Ruling
The Court of Appeals acknowledged the general rule that a regional trial court lacks authority to nullify the decision of a co-equal court (judicial stability). Nevertheless, the CA upheld the RTC’s order because: (1) the petitioner (Republic/LRC) failed to produce records of the alleged cadastral proceedings or the decision; (2) the LRC itself admitted it could not determine the identity of the person adjudicated in that cadastral matter; and (3) the LRC recommended nullification since it could not execute a non-final decision. The CA also emphasized that no third party had asserted ownership, and respondents demonstrated substantial possession of the lot since 1925.
Arguments Advanced by the Parties on Appeal to the Supreme Court
Petitioner’s principal contentions: (1) the RTC lacked authority to nullify a decision of a co-equal court — only the CA may do so; (2) the cadastral court retained exclusive control over its decision and incident matters until issuance of a registration decree; (3) the alleged decision in Cadastral Case No. 33 operates as res judicata and binds respondents and the world; and (4) the RTC’s May 28, 1982 Decision, having become final, could not be altered to nullify another court’s decision (immutability of judgment).
Respondents’ counterarguments: (1) nullification was warranted because, for decades, petitioner failed to produce the cadastral records while respondents substantiated their right to registration; (2) the CA already affirmed the RTC’s order; (3) absence of identity of parties defeats res judicata; and (4) there was no impermissible modification of the RTC’s May 28, 1982 Decision — the August 14, 1996 Order merely effectuated it.
Supreme Court’s Analysis — Judicial Stability Versus Practical Realities
The Court acknowledged the general rule of judicial stability: a court of concurrent jurisdiction may not interfere with a co-equal court’s judgment. Applying that doctrine would render the RTC’s August 14, 1996 Order void if there were in fact an existing, identifiable, final decision in Cadastral Case No. 33. The Court, however, found that the LRC’s report consisted solely of a single entry referencing Cadastral Case No. 33 (LRC (GLRO) Cadastral Record No. 1305) and lacked any supporting records: no copy of the alleged decision, no identification of parties, no indication of court that rendered it, and no decree of registration. Despite more than forty years since the LRC’s initial report, nothing materialized to substantiate the alleged prior adjudication, and no private party stepped forward to claim interest under the supposed cadastral decision.
Reliance on Precedent and Purpose of Land Registration
The Court relied on analogous jurisprudence (Republic v. Heirs of Sta. Ana, G.R. No. 233578, March 15, 2021) in which a prior alleged cadastral adjudication could not be supported by available records and no party claimed the property; the Court allowed subsequent registration to avoid injustice caused by scarcity of records. The Supreme Court emphasized that the decree
...continue readingCase Syllabus (G.R. No. 238338)
Case Caption and Court
- Supreme Court of the Philippines, Second Division, G.R. No. 157719, Decision promulgated March 02, 2022.
- Petition for review assailing the March 20, 2003 Decision of the Court of Appeals in CA-G.R. CV No. 54088.
- Judge/Justice of the Supreme Court who penned the Decision: Hernando, J.
- Concurring justices: Perlas-Bernabe, S.A.J. (Chairperson), Zalameda, Rosario, and Marquez, JJ.
Parties
- Petitioner: Republic of the Philippines, represented by the Office of the Solicitor General (OSG).
- Respondents: Clemente Tapay and Alberto T. Barrion, as the legal representative of the heirs of the deceased Flora L. Tapay.
- Respondent Flora L. Tapay: deceased (passed away on November 21, 1993) and substituted by her heirs.
Subject Property and Basic Facts
- Subject parcel: Lot No. 10786, with an area of 684 square meters.
- Chain of possession alleged by respondents:
- A certain Francisca Cueto possessed the property from 1925.
- Francisca Cueto sold the property to Teofila Lindog (Teofila), respondents' predecessor-in-interest.
- Teofila died intestate in 1971; respondents inherited the property.
- Respondents filed an application for registration of Lot No. 10786 before the Regional Trial Court (RTC) of Lipa City in or about 1980.
- Documents submitted by respondents included muniments of title, tax declaration, and receipts of tax payments.
- Respondents asserted open, continuous, exclusive, and notorious possession in the concept of an owner dating to 1925.
Petitioner’s Contentions (Opposition to Registration)
- The documents offered by respondents (muniments of title, tax declaration, tax receipts) do not constitute competent evidence of acquisition of property.
- Respondents’ possession in the concept of an owner does not establish legal acquisition of title.
- Respondents’ claimed ownership based on a Spanish title or grant is not available because respondents allegedly failed to file the appropriate application within the period set by Presidential Decree No. 892 (entitled “DISCONTINUANCE OF THE SPANISH MORTGAGE SYSTEM OF REGISTRATION AND OF THE USE OF SPANISH TITLES AS EVIDENCE IN LAND REGISTRATION PROCEEDINGS,” dated February 16, 1976).
- The parcel applied for is part of the public domain.
Procedural Postings and Default
- A notice of the application for registration was posted, published, and served upon adjoining property owners.
- The RTC thereafter issued an order of general default “against the whole world.”
LRC / LRA Reports and Cadastral Matter
- The Land Registration Commission (LRC; now Land Registration Authority, LRA) issued a report stating that, based on the Books of Cadastral Lots, the lot was previously subject of registration in Cadastral Case No. 33, LRC (GLRO) Cadastral Record No. 1305, and had allegedly been adjudicated to another person, but the cadastral court had yet to issue a decree of registration.
- The LRC was unable to determine the identity of the person to whom the property was adjudicated because records of the cadastral case, including a copy of the decision, were not available.
- The LRC submitted a supplemental report reiterating the prior cadastral registration entry and recommended that the cadastral court’s decision be nullified so the LRC could issue a decree of registration in favor of respondents.
RTC Proceedings and Decisions
- May 28, 1982 RTC Decision in Land Case No. N-1727, LRC Rec. No. N-35920:
- Upon previous confirmation of the Order of General Default, the RTC adjudicated and decreed the land in favor of and in the names of applicants Flora Tapay and Clemente Tapay, as true and absolute owners, in equal shares pro indiviso.
- Directed that, once the decision became final, the corresponding decree of registration be issued.
- After the May 28, 1982 Decision became final, the RTC directed the LRC to issue the decree of registration and corresponding certificate of title.
- Respondents filed a motion to set aside the decision in Cadastral Case No. 33 to give effect to the May 28, 1982 RTC Decision.
- August 14, 1996 RTC Order (Branch 12, Lipa City): the RTC granted respondents’ motion and set aside the Decision in Cadastral Case No. 33, LRC (GLRO) Cadastral Record No. 1305 relative to Lot No. 10786.
Court of Appeals Ruling
- The petitioner appealed to the Court of Appeals (CA).
- CA’s analysis:
- Acknowledged the general doctrine that an RTC has no authority to nullify the decision of a co-equal court.
- Concluded that doctrine did not apply in the present case because:
- Petitioner (the Republic) could not present the records of the cadastral case.
- The LRC admitted its inability to determine the identity of the party to whom the subject lot was adjudicated.
- The LRC recommended nullification knowing it could not execute the cadastral decision as it never attained finality.
- Noted that no person other than the Republic claimed ownership of the subject property.
- Observed respondents’ evidence that possession by their predecessor-in-interest had been peaceful, open, public, and continuous since 1925.
- CA’s fallo (March 20, 2003): dismissed the appeal for lack of merit and upheld and affirmed the August 14, 1996 RTC Order.
Issues Presented to the Supreme Court
- Primary issue framed by the Court: Did the Court of Appeals err in affirming the RTC’s August 14, 1996 Order setting aside the cadastral court’s alleged decision in Cadastral Case No. 33?
Arguments Advanced by Petitioner to the Supreme Court
- First: The RTC of Lipa City lacked authority to nullify the decision of a co-equal court; only the CA could exercise such power; thus the decision in Cadastral Case No. 33 remains valid and subsisting.
- Second: The cadastral court’s decision and all matters incident thereto remain within the exclusive control of the cadastral court until a registration decree is issued.
- Third: The decision in Cadastral Case No. 33 constitutes res judicata and therefore bars respondents’ application for registration; decisions in cadastral proceedings are binding upon the whole world.
- Fourth: The RTC’s May 28, 1982 Decision, having become final, could no longer be modified to order nullification of the cadastral court’s decision due to the immutability of judgment.
Arguments Advanced by Respondents
- First: The nullification of the cadastral decision should be upheld because from 1982 onwards the Republic failed to produce the cadastral records, while respondents produced sufficient evidence supporting their right to a registration decree.
- Second: The CA, which is empowered to nullify a cadastral court decision, affirmed the RTC’s August 14, 1996 Order; thus the nullification was made within the bounds of law.
- Third: There is a lack of identity of parties and incomplete records to satisfy elements of res judicata or to show that the cadastral decision actually attained finality.
- Fourth: There was no modification of the RTC’s May 28, 1982 Decision; the August 14, 1996 Order effectuated the May 28, 1982 Decision.
Supreme Court’s Holding and Disposition
- The petition is DENIED.
- The March 20, 2003 Decision of the Court of Appeals in CA-G.R. CV No. 54088 is AFFIRMED.
- The Supreme Court agreed with petitioner in principle that an RTC generally has no power to nullify or interfere with the decision of a co-equal court under the doctrine of judicial stability; the August 14, 1996 Order would be void in a typical application of that doctrine.
- The Supreme Court concluded, however, that the doctrine of judicial stability does not find application in this case because:
- Aside from a single entry “Cadastral Case No. 33, LRC (GLRO) Cadastral Record No. 1305,” there are no records, copies of the decision, or identifying information to corroborate the existence, parties, identity of the adjudicated person, or outcome of the alleged cadastral case.
- Key information remained unknown despite the lapse of more than 40 years since the LRC’s initial report.
- No private party has come forward to claim interest arising from the supposed cadastral case.
- Practical considerations were invoked to justify non-disturbance of the RTC proceedings and to leave intact the August 14, 1996 Order.
- The Supreme Court determined that the higher interest of justice is better served by granting respondents’ prayer for a registration decree, particularly when no other person has come forward to dispute their claim even after many years.
Legal Principles and Precedent Applied
- Doctrine of judicial stability:
- The Court recognized the doctrine (citing First Gas Power Corp. v. Republic, 717 Phil. 44, 52 (2013)) that a judgment of a court of competent jurisdiction may not be interfered with by any court of concurrent jurisdiction.
- Rationale: a court that acquires jurisdiction over the case and renders judgment has jurisdiction over its judgment to the exclusion of all other coordinate courts, including execution and control of incidents related to that judgment.
- Limitations on the doctrine where records are unavailable:
- The Court relied on practical considerations and precedent to hold that judicial stability does not apply where alleged prior proceedings cannot be substantiated and no party asserts rights under the supposed prior adjudication.
- Precedent: Republic v. Heirs of Sta. Ana (G.R. No. 233578, March 15, 2021):
- In that case the Republic reported a prior decree of registration but no records existed; the Court allowed subsequent registration, reasoning it would be unjust to hold applicants hostage to scarcity of records and noting the decree of registration, not the decision alone, binds the land.
- Decree of registration vs. decision:
- The Court emphasized that it is the decree of registration that binds the land and quiets title (citing Section 31(2), Presidential Decree No. 1529 (1978) as referenced in the source).
- In the present case, no decree of registration covering the subject land had been issued and the supposed cadastral decision had not even attained finality.
Court’s Reasoning on Res Judicata and Immutability of Judgment
- Res