G.R. No. L-18834; March 29, 1963
Casiano Cano, petitioner-appellee, vs. Julia Mirasol, et al., respondents-appellants.

FACTS

Lot No. 1152, originally owned by Francisca Cabanas, was inherited by Jose Jiloca, who sold it to Jacinto Yniego in 1929. Although the deed was unregistered, Yniego retained the Original Certificate of Title. On January 31, 1937, Yniego sold a 600-square-meter portion of this lot to Casiano Cano, who immediately took possession. However, Yniego’s heirs kept the title. Yniego died on December 23, 1937. It was only on May 23, 1958, that his heirs registered the 1929 sale, resulting in the issuance of Transfer Certificate of Title No. T-25564 in Yniego’s name.
Upon learning of this registration, Cano demanded that Yniego’s heirs surrender the title to the Register of Deeds to annotate his 1937 sale. Upon their refusal, Cano filed a petition on June 2, 1958, in the Court of First Instance of Iloilo, acting as a cadastral court, seeking an order to compel the surrender. The heirs opposed, contesting the sale’s genuineness and arguing that Cano’s right to seek annotation had prescribed. The cadastral court granted Cano’s petition, prompting the heirs’ appeal.

ISSUE

Whether the cadastral court had jurisdiction to hear and decide the petition filed by Casiano Cano.

RULING

The Supreme Court reversed the cadastral court’s order, holding that it lacked jurisdiction over the petition. The legal logic is grounded in the limited jurisdiction of registration courts. Such courts are tribunals of limited powers, primarily tasked with the ministerial function of directing the registration of instruments where no contentious issues are presented. The Court emphasized that when a petition, even one ostensibly filed under Section 111 of the Land Registration Act (Act No. 496), raises controversial and substantive issues—such as the genuineness and due execution of a deed of sale or the defense of prescription—it ceases to be a mere administrative or non-contentious proceeding.
The respondents’ opposition, which disputed the validity of the sale and raised the defense of prescription under Articles 1144 and 2258 of the Civil Code, transformed the matter into an adversarial case requiring the examination of evidence on contentious facts. The Supreme Court, citing precedent including Mendoza v. Abrera, ruled that such issues must be ventilated in an ordinary civil action before a regular court of general jurisdiction. The cadastral court’s duty upon encountering such controversies is to dismiss the petition for lack of jurisdiction, thereby allowing the parties to resolve their dispute in the proper forum. Consequently, the order was set aside.