G.R. No. 157719. March 02, 2022.
REPUBLIC OF THE PHILIPPINES, PETITIONER, VS. CLEMENTE TAPAY AND ALBERTO T. BARRION, AS THE LEGAL REPRESENTATIVE OF THE HEIRS OF THE DECEASED FLORA L. TAPAY, RESPONDENTS.

FACTS

Sometime in 1980, Flora and Clemente Tapay (respondents) filed an application for registration of Lot No. 10786 before the RTC of Lipa City. They claimed ownership through inheritance from Teofila Lindog, who purchased it from Francisca Cueto, alleged to be in possession since 1925. The Republic of the Philippines (petitioner) opposed the application, arguing the land was part of the public domain and the respondents’ evidence was insufficient. The RTC issued an order of general default and, in a Decision dated May 28, 1982, adjudicated the land to the respondents. The Land Registration Commission (LRC) reported that the lot was previously the subject of Cadastral Case No. 33 and had been adjudicated to another person, but no decree of registration had been issued. The LRC could not determine the identity of that person due to missing records. The LRC later recommended nullifying the cadastral court’s decision to allow issuance of a decree in favor of respondents. Consequently, the RTC, in an Order dated August 14, 1996, set aside the decision in Cadastral Case No. 33. The CA affirmed this Order. Petitioner argues the RTC had no authority to nullify a co-equal court’s decision, that the cadastral decision constitutes res judicata, and that the RTC’s 1982 Decision cannot be modified.

ISSUE

Did the Court of Appeals err in affirming the Regional Trial Court’s August 14, 1996 Order which set aside the decision in Cadastral Case No. 33?

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition. While it agreed with the petitioner that, as a general rule, a regional trial court has no power to nullify the decision of a co-equal court under the doctrine of judicial stability, this doctrine finds no application in the present case. The presupposition of a valid, subsisting cadastral decision fails because, aside from a single entry referencing “Cadastral Case No. 33,” no other records—including a copy of the decision, the identity of the parties, or the adjudicating court—exist to substantiate its existence. For over 40 years, no such records have been produced, and no other claimant has come forward to assert an interest from the supposed case. Practical considerations and justice demand that the proceedings in the RTC, where respondents presented evidence of open, continuous, exclusive, and notorious possession since 1925, should no longer be disturbed. This ruling is supported by jurisprudence (Republic v. Heirs of Sta. Ana), where the Court allowed registration despite a claim of prior proceedings due to the absence of records and other claimants. The CA correctly upheld the RTC’s Order.