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    SM Prime Holdings v. Madayag

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    Jerry Cane
    The RTC granted the petitioner's motion to suspend land registration proceedings while awaiting the DENR's resolution of the petitioner's cancellation petition. The CA reversed, finding no basis to suspend proceedings. The Supreme Court affirmed, noting that: 1) Suspending proceedings is only justified to avoid duplicative suits, conflicting judgments, or when a second case cannot be properly decided until the first is resolved, and none of these circumstances were present. 2) Suspending proceedings would delay resolving the land registration case, undermining the purpose of land registration to finally settle title. 3) Under Section 21 of the Land Registration Law, the RTC can require additional facts and papers to aid its determination, and does not need

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    SM Prime Holdings v. Madayag

    Uploaded by

    Jerry Cane
    118 views3 pages
    The RTC granted the petitioner's motion to suspend land registration proceedings while awaiting the DENR's resolution of the petitioner's cancellation petition. The CA reversed, finding no basis to suspend proceedings. The Supreme Court affirmed, noting that: 1) Suspending proceedings is only justified to avoid duplicative suits, conflicting judgments, or when a second case cannot be properly decided until the first is resolved, and none of these circumstances were present. 2) Suspending proceedings would delay resolving the land registration case, undermining the purpose of land registration to finally settle title. 3) Under Section 21 of the Land Registration Law, the RTC can require additional facts and papers to aid its determination, and does not need

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    3. SM Prime Holdings v. Madayag

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    The RTC granted the petitioner's motion to suspend land registration proceedings while awaiting the DENR's resolution of the petitioner's cancellation petition. The CA reversed, finding no basis to suspend proceedings. The Supreme Court affirmed, noting that: 1) Suspending proceedings is only justified to avoid duplicative suits, conflicting judgments, or when a second case cannot be properly decided until the first is resolved, and none of these circumstances were present. 2) Suspending proceedings would delay resolving the land registration case, undermining the purpose of land registration to finally settle title. 3) Under Section 21 of the Land Registration Law, the RTC can require additional facts and papers to aid its determination, and does not need

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    118 views3 pages

    SM Prime Holdings v. Madayag

    Uploaded by

    Jerry Cane
    The RTC granted the petitioner's motion to suspend land registration proceedings while awaiting the DENR's resolution of the petitioner's cancellation petition. The CA reversed, finding no basis to suspend proceedings. The Supreme Court affirmed, noting that: 1) Suspending proceedings is only justified to avoid duplicative suits, conflicting judgments, or when a second case cannot be properly decided until the first is resolved, and none of these circumstances were present. 2) Suspending proceedings would delay resolving the land registration case, undermining the purpose of land registration to finally settle title. 3) Under Section 21 of the Land Registration Law, the RTC can require additional facts and papers to aid its determination, and does not need

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    © All Rights Reserved
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    of 3

    TOPIC: SECTION 21.

    Requirement of Additional Facts

    SM PRIME HOLDINGS, INC., petitioner, vs. ANGELA V. MADAYAG, respondent.


    [G.R. No. 164687. February 12, 2009.]

    MATERIAL FACTS:

    The respondent filed with the RTC an application for registration of a parcel of land.
    Attached to the application was a tracing cloth of survey plan, approved by the land
    Management Services. The petitioner, SM Prime Holdings wrote to the Chief of the Regional
    Survey of Division demanding cancellation of the respondent’s survey because the lot
    encroached on the properties it recently purchased, and it was not notified of the survey
    conducted.

    The petitioner then filed its formal opposition alleging that his parcel of lands was approved
    by the land registration commission and Bureau of Lands. The RTC then declared a general
    default, except as to the petitioner. Thereafter the respondent commenced the
    presentation of evidence.

    The DENR, Assistant Regional Executive Director, acting on the petitioner’s request for the
    cancellation, advised the petitioner to file a petition for cancellation in due form so that the
    DENR could properly act on the same. Accordingly, the petitioner formally filed with the
    DENR.

    The petitioner then filed an Urgent Motion to Suspend Proceedings alleging that that the
    court should await the DENR resolution of the petition for the cancellation of the survey
    plan "as the administrative case is prejudicial to the determination" of the land registration
    case. The RTC granted the motion. Respondent filed a motion for reconsideration but was
    denied. Respondent thereafter filed a petition for certiorari with the CA, in which was
    granted.

    The CA ratiocinated that the survey plan which was duly approved by the DENR should be
    accorded the presumption of regularity, and that the RTC has the power to hear and
    determine all questions arising from an application for registration. The CA denied the
    petitioner’s motion for reconsideration. Hence, this petition for review.

    ISSUE:

    Whether or not the RTC should await the DENR resolution of the petition for the
    cancellation of the survey plan as it is prejudicial to the determination of the land
    registration case.
    RULING:

    WHEREFORE, premises considered, the petition is DENIED. The RTC is DIRECTED to continue
    with the proceedings.

    RATIO DECIDENDI:

    Every order suspending proceedings must be guided by the following precepts:


    it shall be done in order to avoid multiplicity of suits and prevent vexatious litigations,
    conflicting judgments, confusion between litigants and courts, or when the rights of parties
    to the second action cannot be properly determined until the questions raised in the first
    action are settled.

    None of the circumstances that would justify the stay of proceedings is present. In fact, to
    await the resolution of the petition for cancellation would only delay the resolution of the
    land registration case and undermine the purpose of land registration.

    The fundamental purpose of the Land Registration Law (Presidential Decree No. 1529) is to
    finally settle title to real property in order to pre-empt any question on the legality of the
    title — except claims that were noted on the certificate itself at the time of registration or
    those that arose subsequent thereto. Consequently, once the title is registered under the
    said law, owners can rest secure on their ownership and possession.

    As an incident to its authority to settle all questions over the title of the subject property,
    the land registration court may resolve the underlying issue of whether the subject property
    overlaps the petitioner's properties without necessarily having to declare the survey plan as
    void.

    To avoid multiplicity of suits and to promote the expeditious resolution of cases,


    Presidential Decree (P.D.) No. 1529 eliminated the distinction between the general
    jurisdiction vested in the RTC and the latter's limited jurisdiction when acting merely as a
    land registration court. Land registration courts, as such, can now hear and decide even
    controversial and contentious cases, as well as those involving substantial issues.

    The RTC need not wait for the decision of the DENR in the petition to cancel the survey plan
    in order to determine whether the subject property is already titled or forms part of already
    titled property. The court may now verify this allegation based on the respondent's survey
    plan vis-à-vis the certificates of title of the petitioner and its predecessors-in-interest.
    Should the court find it difficult to do so, the court may require the filing of additional
    papers to aid in its determination of the propriety of the application, based on Section 21 of
    P.D. No. 1529:

    SEC. 21. Requirement of additional facts and papers; ocular inspection. — The
    court may require facts to be stated in the application in addition to those
    prescribed by this Decree not inconsistent therewith and may require the filing
    of any additional papers.

    The court may also directly require the DENR and the Land Registration Authority to submit
    a report on whether the subject property has already been registered and covered by
    certificates of title.

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