G.R. No. L-34007. May 25, 1979.
MARCELINO BELAMIDE, et al., petitioners, vs. THE HONORABLE COURT OF APPEALS and BIENVENIDO MONTOYA, et al., respondents.

FACTS

The petitioners, the Belamide siblings, applied for the registration of a parcel of land in Silang, Cavite. The private respondents, the Montoya siblings, filed an opposition. The core dispute centered on the origin of ownership. The land was originally owned by Vicenta Montoya. The petitioners claimed they acquired title from Susana Velardo Belamide, Vicenta’s daughter from her second marriage to Jose Velardo. The respondents asserted their rights as children of Hilarion Montoya, whom they claimed was Vicenta’s legitimate son from her first marriage to Martin Montoya, thus entitling them to a hereditary share. The trial court, after a new trial, adjudicated the land, awarding a three-fourths undivided share to the petitioners and a one-fourth undivided share to the respondents. This decision was affirmed by the Court of Appeals.
The petitioners subsequently moved for a new trial before the Court of Appeals, alleging that a key document (Exhibit 8), which identified Hilarion’s father as Martin Montoya, was falsified. They contended that the official civil registry record showed Hilarion’s father as unknown. The Court of Appeals denied this motion. The petitioners then elevated the case to the Supreme Court via certiorari, arguing grave abuse of discretion in the denial of the new trial and, primarily, that the land registration court lacked jurisdiction to declare heirship and partition the property.

ISSUE

The primary issues were: (1) whether the Court of Appeals committed grave abuse of discretion in denying the motion for new trial based on alleged newly discovered evidence of falsification; and (2) whether a land registration court has jurisdiction to determine questions of heirship and adjudicate shares in the property for registration.

RULING

The Supreme Court dismissed the petition. On the first issue, it found no grave abuse of discretion. The document alleged to be falsified was presented during the trial in the lower court. The petitioners had the opportunity to examine and challenge its authenticity with competent evidence at that time. Their failure to do so, despite the exercise of due diligence, precluded granting a new trial based on evidence that could have been discovered and presented earlier.
On the pivotal jurisdictional issue, the Court ruled that the land registration court properly exercised its jurisdiction. While a land registration court is one of limited jurisdiction, its primary function is to determine the ownership of the land subject to registration. In this case, both the applicants and the oppositors derived their claims from the same original owner, Vicenta Montoya. To resolve the conflicting claims of ownership, the court was necessarily compelled to determine the familial relationships and the corresponding successional rights of the parties. The law does not require a prior separate declaration of heirship from a probate court before applying for land registration. To require such would foster a multiplicity of suits, leading to unnecessary expense and delay.
Furthermore, the petitioners themselves invoked the court’s jurisdiction by filing their application for registration without a prior probate decree. By opposing the application and presenting their own evidence on heirship, the respondents merely participated in the same proceeding. Both parties thereby acquiesced to the court’s exercise of jurisdiction over the issue. Having fully litigated their claims and been given ample opportunity to present evidence, the petitioners could not later assail the court’s authority to decide the very issue they submitted for resolution. The decision, being supported by sufficient evidence, was thus valid.