G.R. No. L-18372; November 29, 1962
THE DIRECTOR OF LANDS, petitioner, vs. ESTEBAN ABAD, ET AL., claimants. BEATRIZ CASTAÑEDA, claimant-respondent-appellee, vs. LEONOR CASTILLO, thru her Guardian Tomas Manuel, claimant-petitioner-appellant.

FACTS

In a cadastral proceeding for Lots Nos. 9102 and 9103 of San Narciso, Zambales, an order of general default was entered on June 12, 1956, after only claimant Beatriz Castañeda appeared. She presented evidence supporting her claim. The following day, June 13, an answer was filed by Tomas Manuel on behalf of the minor Leonor Castillo, asserting her ownership. On June 24, 1956, Castillo, through counsel, filed a motion to set aside the June 12 hearing, alleging Castañeda’s misrepresentation and fraud. Acting on this, the trial court issued an order on September 28, 1956, admitting Castillo’s answer and declaring the two lots contested. Castañeda acquiesced to this order by filing two subsequent motions to set the case for a new hearing.

ISSUE

Whether the trial court erred in adjudicating the lots to Castañeda without conducting a hearing on the merits after having previously declared the lots contested and admitted Castillo’s claim.

RULING

Yes, the trial court committed a reversible error. The legal logic is anchored on due process and the finality of the court’s own interlocutory order. The September 28, 1956 order, which admitted Castillo’s answer and declared the lots contested, had the legal effect of partially lifting the earlier order of default as to Castillo. This order recognized her standing in court and created a contested proceeding requiring a full hearing on the merits. Castañeda’s subsequent motions to set the case for hearing constituted an express acceptance of this contested status. Therefore, the court’s later order of October 15, 1957, which adjudicated the lots to Castañeda without any further hearing and without affording Castillo an opportunity to present her evidence, effectively nullified its own prior final order. This deprived Castillo of her right to be heard, a fundamental component of due process. The Supreme Court set aside the adjudication order and remanded the case to the trial court to conduct further proceedings, allowing Castillo to present her evidence. The technical deficiencies cited by the trial court regarding the verification of the motion to set aside were rendered moot by the court’s own act of admitting the answer and declaring the lots contested, which governed the subsequent course of action.