G.R. No. 22635, October 29, 1927
THE GOVERNMENT OF THE UNITED STATES OF AMERICA, petitioner, vs. THE JUDGE OF THE COURT OF FIRST INSTANCE OF PAMPANGA and THE MANILA RAILROAD COMPANY, respondents.

FACTS

The United States Government, through the Attorney-General, filed a petition for certiorari to annul a decision of the Court of First Instance (CFI) of Pampanga in Cadastral Case No. 6. The CFI had ordered the registration of Lots Nos. 678, 679, 683, and 684 in the name of the Manila Railroad Company. The U.S. Government contended that these lots were part of the Camp Stotsenburg military reservation, which had been established earlier through reservation proceedings (Nos. 10 and 42) under Act No. 627 before the defunct Court of Land Registration. In those proceedings, notices were published, and after the period for filing claims expired, the Court of Land Registration issued an order on June 15, 1914, barring further claims. The Manila Railroad Company did not file any claim during those reservation proceedings. However, when the cadastral case was instituted in 1917, these lots were inadvertently included, and the CFI adjudicated them to the Railroad Company in 1919. The U.S. Government filed a motion to correct this in 1923, but the CFI denied it in 1924 for being filed out of time. The Government then filed this certiorari proceeding in 1926.

ISSUE

Whether the CFI of Pampanga acted without jurisdiction in ordering the registration of the subject lots in favor of the Manila Railroad Company in the cadastral proceedings, considering that these lots were already part of a legally established military reservation.

RULING

Yes, the CFI acted without jurisdiction. The Supreme Court granted the petition for certiorari and declared the CFI’s decision and all related orders and decrees concerning the lots null and void.

The Court held that the establishment of the Camp Stotsenburg military reservation under Act No. 627 was a prior and special proceeding that definitively settled titles within the reservation’s limits. Upon the expiration of the period for filing claims and the termination of those proceedings, the titles to all lands within the reservation were conclusively determined. The cadastral court’s jurisdiction is limited to settling and adjudicating unsettled land titles and does not extend to readjudicating titles already settled by previous proceedings. Since the lots were part of the established reservation, the CFI had no jurisdiction to include them in the cadastral case or to order their registration.

The Court rejected the respondents’ arguments:
1. The claim that the Railroad Company was in visible possession and entitled to personal service of notice in the reservation proceedings was unsupported by evidence and overcome by the presumption of regularity in those proceedings.
2. The defense that the Government lost its right to appeal and was thus barred from seeking certiorari was inapplicable. The rule that certiorari is not available when appeal was lost due to negligence does not apply when the right of appeal is lost through no fault of the petitioner. Furthermore, laches or limitations cannot be invoked against the government when it is asserting its own rights and recovering its own property in the public interest.
3. The issuance of certificates of title to the Railroad Company did not create an indefeasible title because the order of registration, having been issued by a court without jurisdiction, was null and void, and so were the certificates derived from it.

The Supreme Court ordered the cancellation of the certificates of title issued to the Manila Railroad Company.