Heirs of Lichauco v. Director of Lands
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the registration of the hacienda "El Porvenir" in Pangasinan. Initially, Crisanto Lichauco and the Nable Jose sisters applied for registration in 1903. Their application was granted, and a decree of registration and Original Certificate of Title No. 7 were issued based on a 1903 plan by Aurelio Diaz Rocafull. This title was later divided and transferred to various parties, including the heirs of Crisanto Lichauco and the Nable Jose sisters. 2. Procedural History: Following the initial registration and issuance of Title No. 7, the Director of Lands, in 1912, petitioned for a new survey due to doubts about the accuracy of the original survey. This led to a series of court orders and petitions, including a motion by the original applicants to have a private surveyor conduct the new survey at their expense. A new plan (Psu-17590) and technical description were prepared by Zoilo Garcia. Subsequently, in 1922, a motion was filed to cancel existing titles and issue new ones based on the Garcia plan. This was granted, but with modifications and corrections to the plan. Ultimately, an order on March 1, 1923, approved the amended plan (Psu-17590-Amd.), cancelled previous titles, and ordered the issuance of new ones. However, in 1933, a resolution declared the orders of November 24, December 20, 1922, and March 1, 1923, null and void, ordering the cancellation of titles issued under them and the reissuance of titles based on the original Rocafull description. This resolution was affirmed by the Supreme Court in G.R. No. 39512. 3. The Petition: The current petition, filed on August 7, 1934, by the heirs of Crisanto Lichauco and the Nable Jose sisters, seeks to approve an amended plan (Psu-17590-Amd.) and order the correction of Title No. 7 to conform to this amended plan, including the cancellation of the existing title and the issuance of new ones. The oppositors, including the Director of Lands and free patent applicants, argue that the petition constitutes a reopening of a final decree, that the Garcia plan includes public land, and that the matter is res judicata due to a prior Supreme Court decision. The lower court granted the petition, leading to the present appeal.
Issue(s)
Whether the lower court had jurisdiction to entertain and grant the petition of August 7, 1934. Whether the decision of the Supreme Court in Lichauco v. Heirs of Corpuz (60 Phil. 211) constitutes res judicata in the present proceedings.
Ruling
The Supreme Court reversed the order of the lower court, dismissing the petition of August 7, 1934, with costs against the petitioners-appellees. The Court held that the lower court was without authority to entertain, much less grant, the petition as it sought to reopen a decree of registration long closed and settled, and would authorize the inclusion of land not included in the original petition.
Ratio Decidendi
On the issue of jurisdiction to entertain the petition: The Court held that the lower court was without authority to entertain, much less grant, the petition of August 7, 1934. The Torrens system provides that once a decree of registration is made and the time for contest has elapsed, it becomes perfect, conclusive, and irrevocable. Section 38 of Act No. 496 states that every decree of registration binds the land and quiets title, and upon the expiration of one year, it becomes incontrovertible. Section 112 of Act No. 496 permits corrections of errors, omissions, or mistakes in certificates, but explicitly states that it does not give the court authority to open the original decree of registration. The approval of the amended plan Psu-17590-Amd. would not only authorize the inclusion of land of the public domain but also reopen a decree of registration that had long been closed and settled. The Court reiterated that after the issuance of a decree of registration and the judgment has become final, no error can be corrected regarding the area of the land, citing Manlapas & Tolentino v. Llorento. Therefore, what the lower court accomplished was not a correction of an error but a re-trial and the approval of a new decree of registration, which is impermissible. On the issue of res judicata: While the appellants contended that the decision in Lichauco v. Heirs of Corpuz constituted res judicata, the Court found it unnecessary to pass upon this point in view of its conclusion regarding the lack of jurisdiction of the lower court to entertain the petition.
Main Doctrine
A court is without authority to entertain, much less grant, a petition that seeks to reopen a decree of registration long closed and settled, even if it claims to be a mere correction of an error of closure, if such correction would authorize the inclusion of land not included in the original petition or would reopen a settled decree.