GR 26849; (September, 1927) (Digest)
G.R. No. 26849 , September 21, 1927
GOVERNMENT OF THE PHILIPPINE ISLANDS, petitioner-appellant, vs. MARTINO TOMBIS TRIÑO, claimant-appellee.
FACTS
The Government initiated the Sagay cadastral case. In the initial petition, lot No. 1429 was listed as “Public land.” The Director of Lands filed the sole claim for it. During the hearing on May 31, 1923, Martino Tombis Triño filed an answer claiming ownership of a portion of lot No. 1429, describing it vaguely as being within the larger lot and connected to his homestead application. That same afternoon, the court, without receiving any evidence, adjudicated the entire lot to Triño by merely having the interpreter announce “1429: Martino Tombis Triño” and the judge stating “Adjudicado.” A formal decision was later issued in December 1925, incorrectly stating that evidence had been presented. A decree was issued to Triño in June 1926. Prior to the decree, Triño had already sold the lot to Cristeta Ibañez, who later sold it to Leopoldo Escalante. The Government filed petitions to reopen and annul the proceedings, arguing the adjudication was void for lack of jurisdiction and due process. The trial court denied the petitions, prompting this appeal.
ISSUE
Whether the Court of First Instance had jurisdiction to adjudicate lot No. 1429 to Martino Tombis Triño in the cadastral proceeding.
RULING
NO. The Supreme Court reversed the trial court’s order and annulled the adjudication.
The cadastral court lacked jurisdiction to decree the lot to Triño. Jurisdiction over the subject matter in a cadastral case is acquired through the filing of a valid claim or answer. Triño’s answer was fatally defective because it did not claim the entire lot but only an undefined portion of it, making the claim void for vagueness and uncertainty. This defective claim could not serve as a basis for the court’s award of the entire lot. Furthermore, the adjudication was made without any evidence being presented, in violation of fundamental legal principles. The subsequent decision’s recital that evidence was presented was patently false. Since the court never acquired jurisdiction over Triño’s claim to the lot, its judgment was null and void. The fact that the land was later sold to innocent purchasers does not validate a void judgment. The Court ordered the annulment of the decree and all subsequent transfer certificates of title and remanded the case for a new trial.
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