1.

Republic v Sayo 191 SCRA 71

FACTS: The case at bar started at 1961 whe the spouses Casiano and Luz Sandoval filed an
application for a parcel of land, Lot 7454 originally party of Santiago but had since then been
transferred to Nueva Vizcaya. The registration was opposed by Bayaua, Reyes, and the
Philippine Cacao and Farm Products. The case went on until on 1981, 20 years after, the Heirs of
Sandoval, Heirs of Bayaua, and the Bureau of Lands and Bureau of Forest Development entered
a compromise agreement, which effectively distributed parts of lot 7454 among the aforesaid
parties and the counsel of the Heirs of Sandoval as attorney's fees. The compromise agreement
was approved by the court and confirmed the title and ownership of the parties in accordance
with its terms. Having knowledge of the incident, the Solicitor General filed a complaint before
the court to annul the decision rendered by the court a quo for being void and made in excess of
jurisdiction or with grave abuse of discretion. The Solicitor General contended that the the Heirs
of Sandoval et. al. did not present any evidence to support their claims of ownership or
registration, nor did the government agencies involve have a y authority to enter into the
compromise agreement, and finally, that he was not notified of the proceedings and so had not
opportunity to take part therein. As for the Heirs of Sandoval et.al.'s contention, they asseverate
that the land is not a public land as the possessory information title in their name and of their
predecessors- in-interest, the pre-war certification appearing in the Bureau of Archives, and the
fact that the proceeding of the registration was brought under the Torrens act which presupposes
an existing title to be confirmed, are all evidences that the land is a private land.

ISSUE: W/N the respondent's evidences can be considered as proof that the lot 7454 is a private
land.

RULING: NO. Under the Regalian Doctrine 2 all lands not otherwise appearing to be clearly
within private ownership are presumed to belong to the State. Hence it is that all applicants in
land registration proceedings have the burden of overcoming the presumption that the land thus
sought to be registered forms part of the public domain. 3 Unless the applicant succeeds in
showing by clear and convincing evidence that the property involved was acquired by him or his
ancestors either by composition title from the Spanish Government or by possessory information
title, or any other means for the proper acquisition of public lands, the property must be held to
be part of the public domain . 4 The applicant must present competent and persuasive proof to
substantiate his claim; he may not rely on general statements, or mere conclusions of law other
than factual evidence of possession and title.
2. Republic v CA 135 SCRA 156
Facts:
In 1961, the CFI of Quezon rendered a decision, ordering the registration of
885 hectares of public forestland in favor of the Maxinos. The decision became final
and executory so a decree of registration and an OCT were issued. Eight (8) years
after the decision was rendered, the Republic of the Philippines filed with the same
CFI an amended petition to annul the decision, decree, and title on the ground that
they are void because the land in question was still a part of the unclassified public
forest. The Maxinos opposed the petition.
The CFI judge denied the petition and when appealed, the same was
dismissed on the ground that the order had allegedly long become final and
unappealable so the Government was estopped thru the registration made by its
agents.
Issue/s:
Whether or not the Government was estopped in appealing the registration
order.
Ruling: No.
The Government sufficiently proved that the parcel of land involved in the
present case is a part of a forestland, thus non-registerable. As to the ruling of CA
that the government was estopped to appeal because the land was erroneously registered by its
own agency, the Court ruled otherwise basing on its decision in
Gov't. of the U. S. vs. Judge of 1st Inst. of Pampanga, (50 Phil. 975, 980), where it
held that the Government should not be estopped by the mistakes or errors of its
agents.

3. Gomez v CA 168 SCRA 503

Facts:
A court ruling (Philippine Islands vs Abran) settled that 12 parcels of land belonged to one
Consolacion Gomez. Consolacion later died and the 12 parcels of land were inherited by
Jose Gomez et al her heirs. The heirs agreed to divide the property among them.
After notice and publication, and there being no opposition to the application, the trial court
issued an order of general default. On August 5, 1981, the court rendered its decision
adjudicating the subject lots in Gomez et als favor. The decision became final and
executory hence the court directed the Chief of the General Land Registration Office
(GLRO) to issue the corresponding decrees of registration over the lots adjudicated.
GLRO Chief Silverio Perez opposed the adjudication and petitioned for its setting aside. He
discovered that the 12 parcels of land were formerly part of a titled land which was already
granted by homestead patent in 1929. Under the law, land already granted by homestead
patent can no longer be the subject of another registration. The lower court granted
Silverios recommendation.
Gomez et al invoked Sec. 30 and 32 of PD 1529 (Land Registration Act) which provides
that after judgment has become final and executory, the court shall forthwith issue an order
to the Commissioner of Land Registration for the issuance of the decree of registration and
certificate of title. That once the judgment becomes final and executory under Sec 30, the
decree of registration must issue as a matter of course.
ISSUE: Whether or not to set aside the lower courts initial ruling on approving the
adjudication even after it had became final and executory.
HELD: Yes. Unlike ordinary civil actions, the adjudication of land in a cadastral or land
registration proceeding does not become final, in the sense of incontrovertibility until after
the expiration of one (1) year after the entry of the final decree of registration. The Supreme
Court has held that as long as a final decree has not been entered by the Land Registration
Commission (now NLTDRA) and the period of one (1) year has not elapsed from date of
entry of such decree, the title is not finally adjudicated and the decision in the registration
proceeding continues to be under the control and sound discretion of the court rendering it.

4. Cayanan v Estenzo 21 SCRA 1348

FACTS:
On May 30, 1958, the title of appellee De los Santos to Lot No. 56 of the Porac Cadastre was
confirmed by the Hon. Arsenio Santos, then Judge of the Court of First Instance of Pampanga.
On December 16, 1958, a petition for review was filed in the same proceeding alleging that the
said lot was registered in the name of appellee De los Santos "through actual fraud, through
deceit and through intentional omission of facts" as a result of which the aforesaid decision was
rendered and a decree of registration obtained on August 8, 1958. Moreover, it was stated further
that a simulated Deed of Absolute Sale was executed in favor of the other respondent, appellee
Felix L. Camaya, on October 26, 1958, covering the said lot. The prayer was for the opening of
the decree of registration, the cancellation of the Original Certificate of Title, as well as the
Transfer Certificate of Title and the adjudication of said lot in favor of petitioners, now appellant
Cayanan and others. This petition was denied in the order of February 9, 1959, which is on
appeal. It was the view of the lower court: "Such being the case, as admitted by the petitioners,
even [if] the petition has been filed within one (1) year after entry of final decree, the same
cannot be favorably acted upon for the reason that the questioned lot has already been transferred
to Felix L. [Camaya] in accordance with section 38 of the Land Registration Act. While it is true
that the petition states that such transfer is fictitious and, therefore, not for value and that Felix L.
[Camaya] is not an innocent purchaser, this question can be properly threshed out in an ordinary
civil action and not in a simple petition, like the one at bar."

ISSUE: whether or not the cadastral court acting as such could likewise inquire into an
allegation that the lot subject of the decree was transferred in a simulated sale intended to avoid
such a review.

HELD: It can and accordingly reverse the appealed order. The mere mention by the law that the
relief afforded by Section 38 of Act 496 may be sought in 'the competent Court of First Instance'
is no sufficient indication that the petition must be filed in the Court of First Instance, exercising
its general jurisdiction, considering the fact that it is also the Court of First Instance that acts on
land registration cases. Upon the other hand, it has been held that the adjudication of land in a
registration or cadastral case does not become final and incontrovertible until the expiration of
one year from entry of the final decree, and that as long as the final decree is not issued and the
period of one year within which it may be reviewed has not elapsed, the decision remains under
the control and sound discretion of the court rendering the decree, which court after hearing, may
even set aside said decision or decree and adjudicate the land to another." As long as the final
decree is not issued by the Chief of the General Land Registration Office in accordance with the
law, and the period of one year fixed for the review thereof has not elapsed, the title is not finally
adjudicated and the decision therein rendered continues to be under the control and sound
discretion of the court rendering it. In Capio v. Capio, the ruling being to the effect "that the
adjudication of land in a registration or cadastral case does not become final and incontrovertible
until the expiration of one year after the entry of the final decree; that as long as the final decree
is not issued and the period of one year within which it may be reviewed has not elapsed, the
decision remains under the control and sound discretion of the court rendering the decree, which
court after hearing, may set aside the decision or decree and adjudicate the land to another
party." The order was SET ASIDE and the case remanded to the Court of First Instance for a
hearing on the merits of the petition of appellants for the reopening of the decree of registration
in favor of appellee Leon de los Santos.