G.R. No. L-10580; March 27, 1916
TEODORO DE LOS REYES, plaintiff-appellee, vs. MAXIMINO PATERNO, administrator of the estate of Tomas G. del Rosario, deceased, defendant-appellant.

FACTS:
Teodoro de los Reyes filed an action in the Court of First Instance of Manila to be declared the owner of one-half of two parcels of land located in Santa Cruz, Manila, and to require the administrator of the estate of Tomas G. del Rosario to render an accounting of the administration of said properties. The plaintiff claimed an interest in the properties. The defendant, as administrator, denied the material allegations and asserted that Tomas G. del Rosario was the sole owner at the time of his death. The trial court ruled in favor of the plaintiff, ordering the defendant to deliver one-half of one parcel and its rents, and to pay a sum of money representing half the value/rents of the other property. The defendant appealed.

During the trial, the defendant presented as evidence a decree (Exhibit C) from the Court of Land Registration dated September 21, 1909, which ordered the registration of the same two parcels of land under the Torrens system in the name of Tomas G. del Rosario. The plaintiff did not oppose this registration proceeding in 1909, nor did he take any action to challenge the decree or the resulting certificates of title until he filed the present case on February 7, 1914more than four years after the decree became final.

ISSUE:
Whether the decree of registration and the Torrens titles issued in the name of Tomas G. del Rosario constitute res judicata, thereby barring the plaintiff’s claim to an interest in the properties.

RULING:
Yes. The Supreme Court reversed the decision of the trial court and absolved the defendant from liability.

The Court held that the decree of registration issued on September 21, 1909, under Act No. 496 (The Land Registration Act), became final and incontrovertible after the lapse of one year from its entry. Section 38 of Act No. 496 provides that a decree of registration shall be conclusive upon all persons and shall not be reopened or set aside, except for certain specified grounds, after one year from its date. The plaintiff, having failed to (a) appear and oppose the registration proceedings in 1909, or (b) file any petition to reopen or review the decree within the one-year period prescribed by law, forever lost his right to assert any claim or interest in the subject properties, if any such right ever existed. The Torrens title issued to Tomas G. del Rosario is therefore unimpeachable.

The Court distinguished the case from Edroso vs. Sablan (25 Phil. Rep., 295), where claimants of a reservable right (derecho de reserva troncal) properly asserted their claim during the pendency of the registration proceedings. In this case, the plaintiff took no action to protect his alleged interest during the registration or within the statutory period thereafter. The ruling does not abolish the reservable right but emphasizes the necessity of asserting it in the proper forum and within the time fixed by the Land Registration Act. The motion for reconsideration filed by the appellee was subsequently denied.