G.R. No. L-7857; March 27, 1913
MANUEL E. CUYUGAN, petitioner, and LIM TUICO, actual owner, appellees, vs. PEDRO SY QUIA, respondent-appellant.

FACTS

In 1907, the Court of Land Registration issued a decree registering a parcel of land in the name of Manuel E. Cuyugan y Vergara, over the opposition of his neighbor Pedro Sy Quia. Cuyugan later sold the land to Lim Tuico. In 1911, the City of Manila filed an application with the Court of Land Registration, alleging an error of closure in the original survey plan exceeding 1/1500, as it needed to condemn part of the land for a street. The court ordered a resurvey. Based on the new survey plan and evidence presented by the City, Lim Tuico, and Sy Quia, the court issued a new decree in 1912 approving the new plan and ordering the issuance of a new certificate of title to Lim Tuico with a revised technical description. The new plan effectively altered the boundary, taking a portion of land from Sy Quia that had been excluded under the original 1907 decree. Sy Quia appealed.

ISSUE

Whether the Court of Land Registration had the authority, under the guise of correcting an error, to reopen the final 1907 decree, retry the case on new evidence, and issue a new decree altering the boundaries and area of the registered land.

RULING

No. The Court of Land Registration exceeded its authority. The proceeding was not a mere correction of an error in the decree under Section 112 of Act No. 496 (Land Registration Act), but a retrial of the case on new and conflicting evidence. The original 1907 decree was correct and in accordance with the evidence presented at that time. Any alleged mistake was a mistake of fact or evidence, not an error in the decree itself. The fundamental purpose of the land registration system is to settle titles finally and permanently. After a decree becomes final, the Court of Land Registration loses jurisdiction over the land for purposes of adjudicating subsequent disputes, such as boundary controversies between adjoining owners, which are actions in personam that must be brought in ordinary courts. The appealed judgment was reversed and the proceeding dismissed.