SM Prime Holdings v. Madayag. G.R. No. 164687.

February 12, 2009

Facts:
Madayag filed with the RTC of Pangasinan an application for registration of
a parcel of land situated in Urdaneta City, Pangasinan. SM Prime Holdings, Inc. (SM) filed an
opposition to the application alleging that Madayags survey plan encroached from their properties.
Meanwhile, SM filed with the DENR a petition for the cancellation of Madayags survey plan.
SM filed a Motion to Suspend Proceedings, alleging that the RTC should await the DENR
resolution of the petition for the cancellation of the survey plan. The RTC issued an Order granting
the Motion. Madayag filed a petition for certiorari with the CA assailing the RTC Order. CA granted
the petition ordering the RTC to continue proceedings. Thus, SM filed this Petition for Review.
Issue:
Whether the RTC should suspend the proceedings in the land registration
case pending the resolution of the petition for the cancellation of Madayags survey plan filed with
the DENR.
Ruling:
There is no need to suspend the proceedings. When the law confers
jurisdiction upon a court, the latter is deemed to have all the necessary powers to exercise such
jurisdiction to make it effective. It may, therefore, hear and determine all questions that arise from a
petition for registration. The RTC need not wait for the decision of the DENR in the petition to
cancel the survey plan in order to determine whether the subject property is already titled or forms
part of already titled property.
Petition is denied. The RTC is directed to continue with the proceedings.