CACHO v CA (1997)

Melo, J.:
FACTS:
The late Doa Demetria Cacho applied for the registration of two parcels of land situated in what was then
Lanao, Moro Province. Both parcels were within the limits of Military Reservation No. 43 (Camp Overton). The
decision in both cases (Cacho v US) were reserved until the presentation of the deed and the new plan. On
June 1978, petitioner Teofilo Cacho, the son and sole heir of Doa Demetria Cacho, filed a petition for
reconstitution of two original certificates of title under RA 26 which was opposed by respondents Republic,
National Steel Corporation (NSC) and City of Iligan. Acting on the demurrer to evidence filed by Republic and
NSC, the lower court dismissed the petition because it found the evidence inadequate to show the prior
existence of the titles sought to be restored. It stated further that the proper remedy was for the
reconstitution of decrees. It specifically found that since the decrees had been issued, the judgment in Cacho v
US, although by itself expressly dependent upon some conditions, must have indisputably become final.
Thus, petitioner filed an omnibus motion for leave of court to file and to admit amended petition but was
denied. Petitioner elevated the matter to the SC but it resolved to remand the case to the lower court,
ordering the latter to accept the amended petition and to hear it as one for re-issuance of decrees. The lower
court rendered its decision decreeing the reconstitution and re-issuance of Decrees. On appeal, CA reversed
the decision of the lower court and dismissed the petition for re-issuance of Decrees because petitioner failed
to prove: (1) any conduct on their part that would have impelled appellee to act earlier; (2) that they were
misled by appellee's inaction into believing that appellee would not assert the right on which he bases his suit;
(3) the nature of extent of injury or prejudice that would accrue to them in the event that relief is accorded to
the appellee or that the suit is not held barred; and (4) that their claims fall within the metes and bounds of
the property covered by the decree and under the Regalian doctrine, all lands of whatever classification belong
to the state. Hence, the instant petition.

RULING:
The CA is incorrect. Reasons:
1. A land registration proceeding is in rem, and, therefore, the decree of registration is binding upon and
conclusive against all persons including the Government and its branches, irrespective of whether or not they
were personally notified of the filing of the application for registration or have appeared and filed an answer to
said application, because all persons are considered as notified by the publication required by law.
2. A decree of registration that has become final shall be deemed conclusive not only on the questions actually
contested and determined but also upon all matters that might be litigated or decided in the land registration
proceedings. With the certification duly issued by the then Land Registration Commission, the lower court and
the CA correctly found there is no doubt that decrees of registration had in fact been issued in the case at
bench. It is likewise beyond dispute that such decrees attained finality upon the lapse of one year from entry
thereof. To allow the final decrees to once again be subject to the conditions set forth in the 1914 case of
Cacho v US. would be tantamount to setting aside the decrees which cannot be reopened after the lapse of
one year from the entry thereof. Such action would definitely run counter to the very purpose of the Torrens
System.
3. Moreover, to sustain the CA ruling as regards requiring petitioners to fulfill the conditions set forth in Cacho
v U. would constitute a derogation of the doctrine of res judicata. The issuance of the subject decrees
presupposes a prior final judgment because the issuance of such decrees is a mere ministerial act on part of
the Land Registration Commission upon presentation of a final judgment. It is also worth noting that the
judgment in Cacho v US could not have acquired finality without the prior fulfillment of the conditions, the
presentation of the deed and the new plan. Requiring the submission of a new plan as a condition for the re-
issuance of the decree would render the finality attained by the Cacho v US case nugatory, thus, violating the
fundamental rule regarding res judicata. The judgment and the resulting decree are res judicata, and these are
binding upon the whole world, the proceedings being in the nature of proceedings in rem. Besides, such a
requirement is an impermissible assault upon the integrity and stability of the Torrens System of registration
because it also effectively renders the decree inconclusive.
4. As to the issue of laches, suffice it to state that the settled doctrine in this jurisdiction is that laches cannot
bar the issuance of a decree.

REPUBLIC v UMALI (1989)

Cruz, J.:
FACTS:
The land in question is situated in Tanza, Cavite, and consists of 78,865 square meters which was originally
purchased on installment from the government on 1910 by Florentina Bobadilla, who allegedly transferred her
rights thereto in favor of Martina, Tomasa, Gregorio and Julio, all surnamed Cenizal, in 1922. Tomasa and Julio
assigned their shares to Martina, Maria and Gregorio. In 1971, these three assignees purportedly signed a joint
affidavit which was filed with the Bureau of Lands to support their claim that they were entitled to the
issuance of a certificate of title over the said land on which they said they had already made full payment.
Later, a title of certificate was issued in favor of Maria Cenizal, Gregorio Cenizal, and (in lieu of Martina
Cenizal) Rosalina Naval, Luz Naval, and Enrique Naval. When the complaint reversion was filed, the reigistered
owners of the land were Miclat, Pulido and the Navals. They were asked to return the property to the State on
the grounds of forgery and fraud claiming that Gregorio Cenizal having died on February 25, 1943, and Maria
Cenizal on January 8, 1959 could not have signed the joint affidavit dated August 9, 1971. Pulido and the
Navals denied any participation in the joint affidavit and said they had all acquired the property in good faith
and for value. By way of affirmative defenses, they invoked estoppel, laches, prescription and res judicata. For
her part, Miclat moved to dismiss the complaint, contending that the government had no cause of action
against her because there was no allegation that she had violated the plaintiff's right, that the government was
not the real party-in-interest because the subject land was already covered by the Torrens system, and that in
any event the action was barred by prescription or laches.
The respondent court granted the motion to dismiss, thus, petitioner insists that it has a valid cause of
action and that it is not barred by either prescription or res judicata.

ISSUE:
Whether the sale which is tainted with fraud be considered null and void from the start so as to make all
titles derived therefrom also ineffectual ab initio

RULING:
NO. Section 39 of the Land Registration Act clearly provided:
Sec. 39. Every person receiving a certificate of title in pursuance of a decree of registration, and every
subsequent purchaser of registered land who takes a certificate of title for value in good faith shall
hold the same free of all encumbrance except those noted on said certificate.
In the instant case, there is no allegation in the complaint filed by the petitioner that any one of the
defendants was privy to the forged joint affidavit or that they had acquired the subject land in bad faith. Their
status as innocent transferees for value was never questioned in that pleading. Not having been disproved,
that status now accords to them the protection of the Torrens System and renders the titles obtained by them
thereunder indefeasible and conclusive. The private respondents are transferees in good faith and for value of
the subject property and that the original acquisition thereof, although fraudulent, did not affect their own
titles. These are valid against the whole world, including the government.
Moreover, the land being now registered under the Torrens system in the names of the private
respondents, the government has no more control or jurisdiction over it. It is no longer part of the public
domain. The subject property ceased to be public land when a certificate of title was issued to Florentina
Bobadilla in 1910 or at the latest from the date it was sold to the Cenizals in 1971 upon full payment of the
purchase price. As private registered land, it is governed by the provisions of the Land Registration Act, now
denominated the Property Registration Decree, which applies even to the government.
The Torrens system was adopted in this country because it was believed to be the most effective measure
to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is
established and recognized. If a person purchases a piece of land on the assurance that the seller's title thereto
is valid, he should not run the risk of being told later that his acquisition was ineffectual after all. This would
not only be unfair to him. What is worse is that if this were permitted, public confidence in the system would
be eroded and land transactions would have to be attended by complicated and not necessarily conclusive
investigations and proof of ownership. The further consequence would be that land conflicts could be even
more numerous and complex than they are now and possibly also more abrasive if not even violent. The
government, recognizing the worthy purposes of the Torrens system, should be the first to accept the validity
of titles issued thereunder once the conditions laid down by the law are satisfied. As in this case.