G.R. No. L-26235, October 29, 1926 (En Banc)
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

1. The U.S. Government, through reservation proceedings under Act No. 627 , established the Camp Stotsenburg military reservation. Notices were published, and after the period for filing claims expired, the Court of Land Registration issued an order on June 15, 1914, barring all further claims. The Manila Railroad Company (MRR) did not file any claim in these reservation proceedings.
2. In 1917, a cadastral case (No. 6) was instituted in the Court of First Instance (CFI) of Pampanga. Four lots (Nos. 678, 679, 683, 684) that were part of the Camp Stotsenburg reservation were inadvertently included. MRR filed claims for these lots, and in 1919, the CFI ordered their registration in MRR’s name.
3. In 1923, the Attorney-General, on behalf of the U.S. Government, filed a motion in the CFI to correct the decision, arguing the lots were part of the military reservation. The CFI denied the motion in 1924, ruling it was filed too late and the court had lost jurisdiction.
4. The U.S. Government then filed this petition for certiorari, seeking to annul the CFI’s 1919 decision and subsequent orders regarding the four lots, on the ground that the CFI had no jurisdiction to adjudicate lands already settled by prior reservation proceedings.

ISSUE

Whether the Court of First Instance, in a cadastral proceeding, had jurisdiction to order the registration of lands that were already part of a legally established military reservation through prior reservation proceedings under Act No. 627 .

RULING

NO. The petition for certiorari is granted. The decision and orders of the CFI of Pampanga regarding the disputed lots are declared null and void.

1. Lack of Jurisdiction of the Cadastral Court: The Supreme Court held that the CFI, in a cadastral case, had no jurisdiction to readjudicate titles to lands already settled by previous reservation proceedings. The establishment of the Camp Stotsenburg reservation under Act No. 627 was a proceeding specifically designed to settle all claims within the reserved area. Once the period for filing claims expired and the order barring further claims was issued (as happened on June 15, 1914), the titles to all lands within the reservation were definitively settled. The purpose of the Cadastral Act could not extend to overturning titles already settled by a prior special proceeding. The CFI therefore acted in excess of its jurisdiction.

2. Validity of the Reservation Proceedings: The Court found the reservation proceedings regular. Notices were duly published as required by law. MRR’s claim that it was in “visible possession” and thus entitled to personal service of notice was not supported by evidence. The affidavits of the deputy sheriffs and the presumption of regularity prevailed. Furthermore, correspondence from MRR officials in 1910 and 1911 showed the company had actual knowledge of the reservation and the Government’s claim, yet it failed to assert any right during the reservation proceedings.

3. Availability of Certiorari: The Court ruled that the general rule against certiorari when appeal was available did not apply here. The U.S. Government was not a party to the cadastral case and had no opportunity to appeal. Its first opportunity to act was when it discovered the error and filed its motion in 1923. The loss of the right to appeal was not due to its negligence.

4. Defenses of MRR Rejected: The Court rejected MRR’s defenses of laches and the alleged indefeasibility of its Torrens title. A certificate of title issued by a court without jurisdiction over the subject matter is void and confers no valid title. The principle of indefeasibility does not protect a title originating from a void judgment.

DOCTRINE:
A cadastral court has no jurisdiction to adjudicate and order the registration of lands that are already part of a legally established military reservation, the titles to which have been definitively settled by prior reservation proceedings conducted under Act No. 627 . A certificate of title issued pursuant to a judgment rendered by a court without jurisdiction over the res is void and produces no legal effect.