GR L 35780; (January, 1983) (Digest)
G.R. No. L-35780. January 27, 1983. REPUBLIC OF THE PHILIPPINES and THE DIRECTOR OF LANDS, petitioners, vs. HON. NUMERIANO G. ESTENZO, as Judge of the Court of First Instance of Leyte, Branch V, Ormoc City and JAIME D. OMEGA, respondents.
FACTS
The case originated from a petition to reopen cadastral proceedings filed by private respondent Jaime D. Omega on August 20, 1972, concerning Lot No. 5463-B of the Ormoc Cadastre. Omega claimed absolute ownership and actual possession, having acquired the lot by purchase from Alejandro Padayao. He alleged that he and his predecessors-in-interest had been in continuous, immemorial possession and had paid the corresponding taxes. He sought to set aside the original cadastral court decision dated October 31, 1940, which had declared the parent Lot No. 5463 as public land, and prayed for permission to file his own answer to claim the lot.
On September 26, 1972, respondent Judge Numeriano G. Estenzo granted the petition. He set aside the 1940 decision and adjudicated Lot No. 5463-B in favor of Omega and Asuncion Con-Ui. The Republic of the Philippines and the Director of Lands appealed this decision, arguing that the lower court acted without jurisdiction.
ISSUE
Whether or not the Court of First Instance had jurisdiction to reopen the cadastral proceedings and set aside the 1940 decision declaring the lot as public land.
RULING
The Supreme Court ruled that the respondent Judge was without jurisdiction. The legal logic is anchored on the statutory time limits for reopening cadastral proceedings. The original 1940 decision had become final, declaring the lot public land. Republic Act No. 931 , effective June 20, 1953, granted a five-year window—until June 20, 1958—for persons with qualifying claims to petition for reopening. This period was later extended by Republic Act No. 2061 only until December 31, 1968.
Omega filed his petition to reopen on August 20, 1972, which was nearly four years after the absolute deadline of December 31, 1968. No further legislative extension was granted thereafter. Consequently, the right to seek reopening had long prescribed. Since the jurisdictional period had irrevocably lapsed, the lower court lacked the authority to entertain the petition, set aside the final 1940 decision, and adjudicate the land. The 1940 decision thus stands as res judicata. The Supreme Court set aside the 1972 decision as null and void.