Dela Cruz v. Reano
REITERATIONFacts
The Antecedents: In G.R. No. L-29792, Original Certificate of Title (OCT) No. P-1870 was issued on August 18, 1956, in the name of Simeon Gutierrez, covering Lots 1, 2, and 3 of Plan H-105846, which correspond to Cadastral Lots 1896, 1914, and 1913. Petitioners Arsenio dela Cruz, Pedro Sangabol, and Lucia Gutierrez acquired these lots through various transfers and subdivisions, with corresponding Transfer Certificates of Title issued in their names. In G.R. No. L-29866, OCT No. P-275 was issued on July 24, 1948, in the name of Mariano Juan, covering Cadastral Lot 1863. Petitioners in this case are the legitimate children of Mariano Juan, who died in 1965. Procedural History: On May 16, 1966, over ten years after the issuance of OCT P-1870 and nearly ten years after OCT P-275, private respondent Potenciano Reano filed a "Petition for Continuation of Cadastral Proceedings" in Cadastral Case No. 67. He alleged ownership of lands covered by Plan Psu-66102 and prayed for the lifting of a general default order and adjudication of several lots, including Cadastral Lots 1896, 1914, 1913, and 1863, in his favor. On November 16, 1966, the Court of First Instance of Nueva Ecija rendered a decision adjudicating these lots to Reano. Subsequently, Reano filed an ex-parte motion for a writ of possession, alleging that decrees of registration and corresponding original certificates of title had been issued in his name. The writ was granted ex-parte. Petitioners in both cases only learned of these proceedings when the writ of possession was served. They filed motions to set aside the writ and the orders, but these were denied by the respondent judge on October 4, 1968, and October 29, 1968. Consequently, they filed petitions for certiorari. The Petition: Petitioners sought a writ of certiorari to annul the writs of possession and the orders of October 4 and October 29, 1968, and to prevent the enforcement of the writ of possession.
Issue(s)
Whether a parcel of land already titled for more than ten years in the name of a party by virtue of a Homestead Patent issued by the Government in the ordinary course of administrative proceedings can be registered again in the name of another party as a result of subsequent cadastral proceedings. Whether certiorari is the proper remedy to assail a judgment, decree of registration, and certificates of title that are void.
Ruling
The Supreme Court granted the writs of certiorari, set aside the writs of possession issued by the respondent judge, and declared them of no legal effect. The Court ruled that lands already titled by virtue of a homestead patent cannot be re-registered in subsequent cadastral proceedings, and any such second decree is null and void. The Court also held that certiorari is a proper remedy to assail void judgments and titles.
Ratio Decidendi
On the issue of re-registration of already titled land: The Court held that land granted by the Government via a homestead patent, and for which an original certificate of title has been issued, is no longer registerable under the Land Registration Act. Citing Manalo v. Lukban, Et Al., the Court emphasized that a cadastral court has no jurisdiction to decree again the registration of land already decreed and registered in an earlier registration case, rendering any second decree void. Furthermore, the Court noted that the petitioners and their predecessors had been in possession of the land for more than ten years before Reano filed his application, acquiring title by prescription. The issuance of homestead patents and original certificates of title in their names, in the ordinary course of administrative proceedings, presumed due performance of official duty and were entitled to full credit absent proof of illegality or fraud. Therefore, the registration decreed in Reano's name and the certificates of title issued to him were null and void, and he had no right to the issuance of writs of possession. On the propriety of certiorari: The Court found Reano's contention that certiorari is not the proper remedy to be untenable. The Court reasoned that since the judgment rendered in Reano's favor, the decree of registration, and the certificates of title issued to him were all void, certiorari was the appropriate remedy to assail these void acts. The fact that the titles were allegedly based on an informacion possessoria did not alter the situation, as the issuance of such an instrument does not remove the land from the public domain by itself.
Main Doctrine
Land already titled for more than ten years by virtue of a Homestead Patent issued by the Government in the ordinary course of administrative proceedings cannot be registered again in the name of another party as a result of subsequent cadastral proceedings. A second decree for the same land is null and void.