G.R. No. 47789 ; June 10, 1941
FE CASTRO DE AGBAYANI, petitioner, vs. THE JUSTICE OF THE PEACE OF THE CAPITAL OF THE PROVINCE OF ILOCOS NORTE, MACONDRAY & CO., INC., and DAMASO RUBIO, respondents.

FACTS

In Cadastral Case No. 51 of Ilocos Norte (G.L.R.O. Cad. Record No. 1212), the Justice of the Peace of the capital of said province, acting in place of the Court of First Instance under the authority of Act No. 4090 , rendered a decision on August 27, 1934. This decision adjudicated Lot No. 10779, with an area of 1,940 square meters, to Fe Castro Galang, Macondray and Company, and Damaso Rubio in specified portions. The lot was claimed by these three parties, with Macondray & Co., Inc. claiming one-fourth undetermined portion plus the house thereon, Damaso Rubio claiming 700 square meters plus a house under construction, and Fe Castro de Agbayani claiming 1,240 square meters. The lot was therefore the subject of controversy among them. Despite this, the Justice of Peace adjudicated the lot as indicated in his decision without first hearing the petitioner, Fe Castro de Agbayani, who was neither informed of the hearing nor notified of the decision after its promulgation, even though her claim was part of the record.

ISSUE

Whether the Justice of the Peace had jurisdiction and authority to hear and decide the cadastral case regarding Lot No. 10779, which was disputed and whose value exceeded two thousand pesos (P2,000).

RULING

The Supreme Court granted the petition for certiorari. The Court held that under Act No. 4090 , a justice of the peace could only be delegated by the Court of First Instance to hear and decide cadastral cases involving parcels that are not the subject of controversy or opposition, or disputed parcels whose value does not exceed two thousand pesos (P2,000). Based on the claim documents in the cadastral record, the portion of the lot claimed by Damaso Rubio alone was valued at P8,700, and the portion claimed by Macondray & Co., Inc. was valued at P2,003. Therefore, because the value of the lot in question greatly exceeded P2,000 and because there was a controversy regarding its ownership, the Justice of the Peace of the capital of Ilocos Norte lacked the jurisdiction and authority delegated to him by the Court of First Instance to act on the case concerning said lot. Only the Judge of the Court of First Instance in his own right could hear and decide the controversy, after first hearing all interested parties. Consequently, the decision and ruling of the Justice of the Peace regarding Lot No. 10779 of Cadastre No. 51 of Ilocos Norte are null and void, as are all acts derived therefrom, such as Registration Decree No. 652283 and Original Certificate of Title No. 7301 of the Province of Ilocos Norte. The Court cited the precedent in Government of the United States vs. Judge of First Instance of Pampanga (50 Phil., 1012), which states that when a court lacks jurisdiction to order registration, the certificates of title issued pursuant to such order are null and ineffective.
The Court declared null and void the decision and ruling of the Justice of the Peace on Lot No. 10779, as well as Registration Decree No. 652283 and Original Certificate of Title No. 7301. It ordered that the cadastral record be heard anew regarding said lot in the Court of First Instance so that the claims of the petitioner and the respondents Macondray & Co., Inc. and Damaso Rubio may be determined and decided by the Judge in his own right, after necessary proceedings. It further ordered that Original Certificate of Title No. 7301 be returned and delivered to the Register of Deeds of Ilocos Norte by whoever holds it, for cancellation. No costs were awarded.