G.R. No. L-11527; February 16, 1917
THE ROMAN CATHOLIC ARCHBISHOP OF MANILA, petitioner-appellant, vs. JOSE RUIZ SUNICO, objector-appellant, and TEODORO CATLI, tutor and “curador ad litem” of Liberata Catli, objector-appellee.

FACTS:
The Roman Catholic Archbishop of Manila filed an application for registration of a large tract of land under the Land Registration Act. Two oppositors contested the application: (1) Teodoro Catli, representing the minor Liberata Catli, and (2) Jose Ruiz Sunico.

2. As to Jose Ruiz Sunico: He claimed a portion of the same tract. The Archbishop’s evidence of ownership consisted only of vague oral testimony from the parish priest and a sacristan, alleging possession for over forty years. Sunico presented documentary evidence suggesting ownership, including a prior court judgment in his favor against the parish priest regarding possession of the land. The trial court excluded this evidence for insufficient proof of identity between the land in the prior case and the land in dispute.

ISSUE:
1. Whether the trial court erred in setting aside its initial decree and granting a new trial for the minor Liberata Catli.
2. Whether the trial court erred in excluding Sunico’s evidence and in adjudicating the disputed portion in favor of the Archbishop.

RULING:
1. Regarding Liberata Catli’s appeal: The Supreme Court affirmed the trial court’s decision. The initial decree was not final and unappealable because a motion for new trial was filed within the allowable period. Under Section 14 of Act No. 496 (as amended), the trial court retained jurisdiction to alter or amend its decision before it became final. The minor’s documented title and possession outweighed the Archbishop’s weak oral evidence.

2. Regarding Jose Ruiz Sunico’s appeal: The Supreme Court reversed the trial court’s decree as to Sunico’s claimed portion and ordered a new trial. The Archbishop’s evidence was insufficient to meet the stringent standard of proof required for land registration. The trial court erred in excluding Sunico’s evidence of prior litigation, which could have cast doubt on the Archbishop’s claim of undisturbed possession. The identity of the lands should be re-examined upon retrial.

DISPOSITIVE:
– The decree adjudicating the minor Catli’s land in her favor is affirmed.
– The decree regarding Sunico’s claimed portion is reversed, and the case is remanded for a new trial on that issue.
– Costs awarded against the Archbishop in the Catli appeal; no special costs in the Sunico appeal.

SEPARATE OPINION:
Justice Moreland dissented without stating reasons.