G.R. No. L-58822 April 8, 1988
Republic of the Philippines, petitioner, vs. Hon. Angel G. Sangalang, as Presiding Judge, Court of First Instance of Baguio and Benguet, Branch I; Sps. Mariano Kiang, and Miranda Soble; et al., respondents.

FACTS

The subject property, located within the Baguio Townsite Reservation, was claimed by the Kiang family through inheritance from ancestors allegedly in possession since Spanish times. In 1916, the patriarch applied for its registration. This application, docketed as Case No. 30, was subsumed under the compulsory registration proceedings of Civil Reservation Case No. 1, initiated in 1912 under specific public land acts to settle all claims within the Baguio Reservation. On November 13, 1922, the court in Civil Reservation Case No. 1 rendered a decision declaring all lands within the reservation as public, except those specifically adjudicated as private. The Kiang property was not adjudicated as private; thus, it was declared public land, and the Kiangs’ specific application was dismissed.
Decades later, on October 1, 1953, the respondent Kiangs filed a new application for registration of the same parcels, docketed as Land Registration Case No. N-30. On February 16, 1970, the court, presided by Judge Pio R. Marcos, adjudicated the land in their favor, leading to the issuance of Original Certificate of Title No. 0-280 on June 5, 1975. The Republic subsequently filed a complaint to annul this 1970 decision and the resulting titles, arguing that the 1922 decision in Civil Reservation Case No. 1 was conclusive and barred the later application. The trial court dismissed the Republic’s complaint, prompting this appeal.

ISSUE

The core issue is whether the court in Land Registration Case No. N-30 had jurisdiction over the subject matter, considering the prior final judgment in Civil Reservation Case No. 1 which had declared the property public land.

RULING

The Supreme Court granted the petition, reversed the trial court’s decision, and ordered the nullification of the titles. The legal logic is anchored on the principle of jurisdiction and res judicata. Jurisdiction over the subject matter is conferred by law and cannot be waived. The 1922 decision in Civil Reservation Case No. 1, a compulsory registration proceeding under Act No. 926, conclusively settled the status of all lands within the Baguio Townsite Reservation. By declaring the Kiang property public land and dismissing their application, that decision became final and vested title over the land in the government. Consequently, the property ceased to be alienable and registrable under a subsequent voluntary registration proceeding.
Therefore, when the Kiangs filed Land Registration Case No. N-30 in 1953, they were seeking registration of land that was already adjudged as public domain. The court in that later case had no jurisdiction to entertain an application for registration of inalienable public land. All proceedings in Land Registration Case No. N-30, including the 1970 decision and the titles issued, were null and void ab initio for lack of jurisdiction. The defense of indefeasibility of a Torrens title does not apply where the decree of registration was issued by a court without jurisdiction. Furthermore, Presidential Decree No. 1271, which provided a mechanism to validate certain titles issued from reopened Baguio cases, did not apply as the Kiangs’ title was issued in 1975 and they failed to show compliance with its validation requirements.