G.R. No. 20151; March 6, 1923
THE DIRECTOR OF LANDS, as representative of the Government of the Philippine Islands, petitioner, vs. Honorable FRANCISCO SANTAMARIA, as Judge of the Court of First Instance of Iloilo, and JULIO JAVELLANA, respondents.

FACTS

In Cadastral Case No. 1 of Iloilo, lots Nos. 3462 and 3463 were declared public lands in a decision dated May 23, 1916. Over five years later, on December 24, 1921, respondent Judge Francisco Santamaria, upon petition of respondent Julio Javellana, revoked the order of general default and the 1916 decision regarding those lots, permitting Javellana to file his claim. Subsequently, on October 9, 1922, the same judge rendered a new decision ordering the registration of the lots in Javellana’s name. The Director of Lands, through the Attorney-General, filed a motion in the lower court to declare the 1922 decision null and void, which was denied on November 18, 1922. The Director of Lands then filed this petition for certiorari, alleging the lower court exceeded its jurisdiction.

ISSUE

Whether the Court of First Instance exceeded its jurisdiction in revoking the order of general default and the final 1916 decision in a cadastral case after more than five years, and in ordering the registration of the lots in favor of a private claimant.

RULING

Yes. The lower court exceeded its jurisdiction. A court has no jurisdiction to set aside an order of default and reopen a cadastral case years after the decision therein has become final. Consequently, the order of December 24, 1921, and the decision of October 9, 1922, were null and void ab initio and could not attain finality. The petition for certiorari was granted, and the said orders and decision were declared null and void.