GR L 5188; (February, 1910) (Digest)
G.R. No. L-5188
LINO ALINDOGAN, ET AL., petitioners-appellees, vs. THE INSULAR GOVERNMENT, respondent-appellant.
February 10, 1910
FACTS:
On March 7, 1906, Lino Alindogan and Lino Alindogan Jac-Teoco filed a petition for the registration of a parcel of land measuring 5,172 square meters. The Solicitor-General, representing the Director of Public Lands (Insular Government), appeared and requested to be made a party to the proceedings. After hearing the evidence presented by the petitioners, the lower court rendered a judgment declaring them the absolute owners of the land, overruling the opposition of the Director of Lands, and decreeing the registration of the land in their favor, subject to an easement of way.
The Insular Government (respondent-appellant) excepted to this judgment and filed a motion for a new trial, arguing that the evidence was insufficient to justify the court’s conclusions. The motion was denied. The government then appealed to the Supreme Court, assigning as error that the Court of Land Registration failed to make any finding of facts in its judgment.
ISSUE:
Did the lower court commit reversible error by failing to include a finding of facts in its judgment, as required by law?
RULING:
Yes. The Supreme Court found that the lower court’s judgment contained no finding of facts upon which its conclusions were based, which is a direct violation of Article 133 of the Code of Procedure in Civil Actions ( Act No. 190 ). The Court reiterated its consistent doctrine, established in previous cases, that a trial court’s failure to make a finding of facts constitutes reversible error.
However, recognizing that no other opposition was presented during the trial and that the petitioners were not responsible for the error, the Court did not reverse the substance of the lower court’s decision. Instead, the case was remanded to the lower court with specific instructions:
1. To make a finding of facts based solely on the evidence already adduced during the trial, without the need for presenting additional proof.
2. Once the finding of facts is made, to register the title in accordance with the conclusions in the original decision of the lower court.