Bernardo v. Dizon
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns ownership and partition of several parcels of land. Initially, a complaint was filed demanding partition and annulment of conveyance of unregistered riceland and a residential lot, formerly owned by deceased spouses Miguel Bernardo and Lorenzo Garcia. This led to a declaration of community property by the Court of Appeals, later affirmed by the Supreme Court, allocating portions to different heirs. 2. Procedural History: A separate application for registration of Lot 4519 of the Paranaque Cadastre was filed, leading to oppositions from the Director of Lands and private parties. A Stipulation of Facts and Agreement was executed, and a decision was rendered based on it, adjudicating specific portions. A Decree of Registration was issued, followed by Original Certificate of Title to private respondents. Petitioners filed a petition to set aside the decree and the trial court's decision, alleging fraud and claiming the land was already adjudicated to them. This petition was denied, as was a subsequent motion to amend and an appeal. The property was later subdivided, and a portion was sold to Saint Martin Management & Development Corporation (SMMDC). SMMDC sought a writ of possession, leading to a compromise with one petitioner, which was later set aside. Petitioners then moved to cancel titles and issue new ones in their names, which was denied, with the court suggesting a separate action. A cease-and-desist order was issued against SMMDC and Elvira Reyes, which was later reviewed by the Court of Appeals. 3. The Petition: Two consolidated appeals by certiorari are before the Supreme Court. G.R. No. L-75877 is an appeal from the Court of Appeals' decision, and G.R. No. L-77677 is a direct appeal from the Regional Trial Court. The petitioners argue that Lot 4519 was already adjudicated to them by a final Supreme Court judgment. However, the Supreme Court notes that the appeal in G.R. No. L-75877 was filed late. The appeal in G.R. No. L-77677 challenges the Court of Appeals' decision annulling cease-and-desist orders and enjoining further proceedings, but the Supreme Court finds that the decree of registration is final and unalterable, and the petition to set it aside was filed beyond the statutory period.
Issue(s)
Whether the petition to set aside the decree of registration was filed within the statutory period. Whether the appeal from the order denying the petition to set aside the decree of registration was timely filed. Whether the Court of Appeals erred in annulling the cease-and-desist orders issued by the Regional Trial Court.
Ruling
Both petitions for certiorari are dismissed for lack of merit.
Ratio Decidendi
On the timeliness of the petition to set aside the decree of registration: The Court held that the decree of registration was issued on September 10, 1982. The petitioners filed their petition to set aside the decree on July 14, 1983, which was ten months and four days after its issuance. This petition interrupted the finality of the decree, leaving a balance of one month and twenty-six days to complete the one-year period for review. However, the order denying the petition to set aside the decree became final on February 10, 1984. Thereafter, the one-year period for the finality of the decree of registration resumed running and was completed on April 6, 1984, making the decree of registration final and irrevocable. Therefore, any subsequent attempt to reopen it was legally impermissible. On the timeliness of the appeal from the order denying the petition to set aside the decree: The Court found that the appeal by certiorari in G.R. No. 75877 was filed on March 29, 1987, nine months after the court issued the order of June 6, 1986. This was clearly late, rendering the appeal dismissible on that ground alone. On the Court of Appeals' annulment of the cease-and-desist orders: The Court found no reversible error in the Court of Appeals' decision annulling the cease-and-desist orders. The appellate court correctly noted that the decree of registration had long become final and unalterable. The Regional Trial Court's attempt to entertain further pleadings or motions relative to the review of this final decree was deemed improper. The Court of Appeals' action in permanently enjoining the trial court from further entertaining such pleadings was therefore justified.
Main Doctrine
A petition to set aside a decree of registration filed beyond the statutory one-year period for review, after the period for finality of the decree has resumed running and been completed, is dismissible. Similarly, appeals from orders denying such petitions, if not seasonably filed, are also dismissible.