G.R. No. L-16928; September 30, 1963
GREGORIO GUECO, ET AL., plaintiffs-appellees, vs. ATANASIA VDA. DE LACSON, ET AL., defendants, ATANASIA VDA. DE LACSON, defendant-appellant.

FACTS

The case involves a parcel of land originally owned by Faustina Baron. In a 1928 cadastral decree, the land was registered in her name but subject to a “reserva troncal” in favor of certain relatives of her predecessor, Felix Layug, specifically the Gueco and Gantioqui families. This reservation was annotated on the original certificate of title. In 1949, Faustina Baron sold the land to her only son, Emilio B. Lacson, and the annotation regarding the reserva troncal was carried over to his transfer certificate of title. Emilio Lacson died in 1952, and Faustina Baron died in 1955. The plaintiffs, claiming to be the surviving reservees (reservatarios), demanded from the defendant, Atanasia Vda. de Lacson, as executrix of Emilio’s estate, the segregation and delivery of the reserved portion. The defendant refused, arguing the plaintiffs were not relatives within the third degree of the prepositus and that the cadastral court had no jurisdiction to declare the reservees at the time of registration.

ISSUE

The primary issue is whether the cadastral court had jurisdiction to declare the existence of the reserva troncal and identify the reservees in its 1928 decree, and whether the plaintiffs, as reservees, are entitled to enforce that reservation against the estate of Emilio Lacson.

RULING

The Supreme Court affirmed the lower court’s judgment, ruling in favor of the plaintiffs. The Court held that the cadastral court did have jurisdiction to determine and declare the existence of the reserva troncal and the identities of the reservees at the time of the land registration proceedings. While the defendant correctly cited the general civil law principle that the right of reservees vests only upon the death of the reservist (Faustina Baron), this does not strip the registration court of its statutory power under the Land Registration Act to hear and determine all questions affecting the title to the land applied for registration, including existing future interests like a reserva troncal. The 1928 decree, which had long become final, conclusively established the reservable character of the portion in favor of the named reservees. Consequently, all parties, including the appellant, are barred from contesting the constituent elements of the reserve. The only conditions for the plaintiffs’ title to ripen were the deaths of the reservist (Faustina) and their survival of her, both of which were satisfied. The annotation on the title served as constructive notice to all subsequent purchasers, including Emilio Lacson. Therefore, the defendant, as executrix, is obligated to segregate and convey the reserved property to the plaintiffs.