G.R. No. L-13687. November 29, 1963. REPUBLIC OF THE PHILIPPINES, petitioner-appellant, vs. SEGUNDO SIOSON and PASCUALA BAUTISTA, respondents-appellees.
FACTS

The spouses Segundo Sioson and Pascuala Bautista filed an application for registration of four parcels of land. The Director of Lands opposed the registration of Lot No. 4, claiming it was part of the public domain. The trial court adjudicated Lots 1, 2, and 3 to the spouses but made no adjudication for Lot No. 4. The spouses appealed the non-adjudication of Lot No. 4 to the Court of Appeals. During that appeal, the Solicitor General, representing the Director of Lands, filed a pleading recommending that the registration of Lot No. 4 be decreed in favor of the spouses. Consequently, the Court of Appeals rendered judgment modifying the trial court’s decision and ordering the registration of Lot No. 4. The corresponding decree was issued.
One year later, the Republic, through the Solicitor General, filed a petition in the trial court for review of the decree and cancellation of title over Lot No. 4. The petition alleged that the registration was secured through actual and extrinsic fraud, involving intentional concealment of facts and connivance with a land inspector. The respondents opposed, arguing, among other grounds, res judicata, lack of jurisdiction of the trial court to review a final judgment of the Court of Appeals, and that the Solicitor General was in estoppel due to his earlier recommendation for registration. Without conducting a hearing or receiving evidence, the trial court denied the Republic’s petition for review.

ISSUE

Whether the trial court erred in dismissing the petition for review of decree without conducting a hearing to allow the Republic to present evidence on its allegation of actual and extrinsic fraud.

RULING

Yes, the trial court committed reversible error. The Supreme Court set aside the trial court’s order and remanded the case for further proceedings. The petition for review was filed within the one-year period allowed by law, specifically predicated on allegations of actual and extrinsic fraud. When a petition for review alleges such fraud, the court is obligated to conduct a hearing and receive evidence to determine the veracity of the claims. The trial court’s summary denial without affording the petitioner an opportunity to prove its allegations was improper. The Court clarified that the defenses raised by the respondents, including estoppel and res judicata, pertained to the merits of the petition and should be properly ventilated in a full hearing. Furthermore, the Supreme Court noted a significant substantive point: if Lot No. 4 was indeed part of the bed of a navigable stream or river, it would be part of the public domain incapable of private appropriation or registration under the Land Registration Act. This legal issue also necessitated a factual determination through a proper hearing. The case was therefore remanded to the trial court to receive evidence and proceed in accordance with law.