G.R. No. L-22115, December 29, 1971
BENITO YLARDE, et al., petitioners, vs. CRISANTO LICHAUCO, et al., and THE HON. AMADO S. SANTIAGO, respondents.

FACTS

This case originates from a protracted land registration proceeding (Land Case No. 1, G.L.R.O. Record No. 1). Petitioners, claiming to be heirs and successors of original oppositors, sought to assert individual claims within the Hacienda “El Porvenir.” They filed motions to locate and survey their claims and opposed a court-ordered relocation survey (the Llobrera Plan), arguing it deviated from the original Rocafull Plan and failed to plot their adverse claims. The respondent Judge, after hearings, issued an order dated March 12, 1963, approving the Llobrera Plan as substantially in accordance with a prior Supreme Court decision.
Subsequently, petitioners filed a “Motion to Proceed with the Hearing on the Merits,” arguing that the plan’s approval did not adjudicate title and that they should be allowed to present evidence on their claims. They emphasized that the original certificate of title (OCT No. 7) based on the Rocafull Plan had been cancelled. The trial court initially set the case for hearing but, upon opposition from the applicants (respondents Lichauco, et al.), reconsidered and issued orders dated August 5 and 23, 1963, effectively denying petitioners’ motion to proceed. This prompted the instant petition for certiorari, prohibition, and mandamus.

ISSUE

Whether the respondent Judge committed grave abuse of discretion in issuing the orders of August 5 and 23, 1963, which denied petitioners’ motion for a hearing on the merits of their claims.

RULING

The Supreme Court dismissed the petition. The legal logic is anchored on the finality and conclusiveness of the original decree of registration. The Court held that the core issue of ownership and the validity of the applicants’ title to the hacienda had been conclusively settled by the decree of registration (Decree No. 1178) issued in the very same land registration case. This decree, which became final long ago, adjudicated the land in favor of the applicants and foreclosed all opposing claims.
The proceedings subsequent to that final decree, including the approval of the Llobrera relocation survey plan, were merely incidental and administrative in nature, aimed at implementing the already-adjudicated rights. The purpose of the relocation was solely to ascertain if the land described in the new survey was the same land previously decreed, not to reopen the adjudication of title. Consequently, petitioners’ motion for a hearing to present evidence on their claims sought to relitigate matters already barred by the prior final decree. The respondent Judge, therefore, did not act with grave abuse of discretion in denying a hearing that would serve no legal purpose. The titles derived from the cancelled OCT No. 7 were declared void in a prior case, but this did not nullify the underlying decree of registration itself, which remained the source of the applicants’ vested rights.