G.R. No. L-36637 July 14, 1978
Generoso Mendoza, substituted by his wife and administratrix Diega de Leon Vda. de Mendoza, petitioner, vs. The Hon. Court of Appeals, Daniel Gole Cruz and Dolores Mendoza, respondents.

FACTS

Generoso Mendoza filed an application for registration of two parcels of land. After publication and hearing, with no opposition, the court entered an order of general default. During the pendency of the case, Mendoza sold the properties to spouses Daniel Gole Cruz and Dolores Mendoza, reserving usufructuary rights. The deed of sale was presented as evidence in the registration proceedings. Based on this evidence, the registration court rendered a decision ordering the registration of the land in the names of the vendee-spouses, subject to the vendors’ usufruct. A decree and an Original Certificate of Title were subsequently issued in the vendees’ names.
After the decree became final, Mendoza filed a petition for reconsideration, treated as a petition for review of the decree, alleging the vendees failed to pay the purchase price. The registration court granted the petition, set aside its decision and the decree, and ordered the cancellation of the title. It ruled it lacked jurisdiction to order registration in favor of the vendees as they were not parties to the application. The Court of Appeals reversed this order, reinstating the decision and title in favor of the vendee-spouses. Mendoza appealed to the Supreme Court.

ISSUE

Whether the registration court had jurisdiction to order the registration of the land in the names of the vendee-spouses, who were not formal parties to the original application.

RULING

Yes. The Supreme Court affirmed the decision of the Court of Appeals. The core legal principle is that a court in a land registration case has the authority to order the issuance of a decree in the name of the person proven to be the actual owner, even if that person is not the original applicant, provided the evidence presented supports such adjudication and there is no prejudice to third parties. In this case, the applicant-vendor himself presented the deed of sale as evidence, thereby providing the factual and legal basis for the court to adjudicate the title in favor of the vendees. The vendees, though not formally named as applicants, were the real parties in interest established by the evidence. The court’s decision conformed to the evidence presented, and its jurisdiction over the res (the land) allowed it to determine ownership based on that evidence. The failure to formally amend the application was a procedural technicality that did not invalidate the substantive adjudication, especially since the vendees’ rights arose from the applicant’s own voluntary act of sale and presentation of the deed. The petition was denied.