GR L L 34501; (December 1975) (Digest)
G.R. No. L-34501, December 17, 1975
Republic of the Philippines, petitioner, vs. Hon. Abraham P. Vera, as Judge of the Court of First Instance of Bataan, Branch I, Evelyn M. Eugenio and Elizabeth M. Eugenio, respondents.
FACTS
The private respondents filed a “Petition for Re-adjudication and/or New Hearing” on February 18, 1971, concerning Lot 501 of the Mariveles Cadastre. They claimed ownership through purchase from predecessors who allegedly failed to file an answer in the original cadastral proceedings, leading to a 1937 decision declaring the lot public land. They asserted that a motion for reconsideration of that decision was pending when the judicial records were destroyed during World War II. The petitioner Republic opposed the petition and moved to dismiss, arguing the court lacked jurisdiction because the statutory period for reopening such proceedings had expired.
The respondent court denied the motion to dismiss and, after hearing, adjudicated the lot to the private respondents. The Republic appealed, contending the petition was effectively a belated attempt to reopen cadastral proceedings under inapplicable laws and that the failure to reconstitute the lost records within the periods provided by law was fatal.
ISSUE
Whether the respondent court acquired jurisdiction to entertain the private respondents’ petition for re-adjudication and/or new hearing filed in 1971.
RULING
No, the respondent court lacked jurisdiction. The Supreme Court ruled that the petition, despite its title, was in substance a petition to reopen the cadastral proceedings. The applicable law for such reopening was Republic Act No. 931 , which allowed claims within a specified period. This period expired on December 31, 1968, and was not extended by subsequent legislation. Since the petition was filed only on February 18, 1971, the right to initiate the action had already prescribed. Consequently, the court did not acquire jurisdiction over the petition.
The Court further noted that the private respondents’ failure to reconstitute the destroyed records within the periods mandated by Republic Act No. 441 (until June 7, 1951) and Republic Act No. 3081 (until June 18, 1963) precluded any revival or continuation of the original case. This failure cast doubt on their claim of a pending motion for reconsideration. Thus, the decision of the respondent court was set aside and the petition dismissed.