GR L 46247; (April, 1939) (Digest)
G.R. No. L-46247; April 4, 1939
THE SAN JUAN DE DIOS HOSPITAL, applicant-appellee, vs. THE MUNICIPAL COUNCIL OF SAN RAFAEL and THE MUNICIPAL COUNCIL OF SAN ILDEFONSO, both of the Province of Bulacan, petitioner-appellants.
FACTS
The Municipal Councils of San Rafael and San Ildefonso filed an “Adverse Claim and Escheat” motion in the Land Registration Court, seeking the cancellation of Original Certificates of Title Nos. 428 and 494 issued in favor of San Juan de Dios Hospital. They alleged that the Hospital, not being a juridical person, lacked legal capacity to apply for registration of the Buenavista Hacienda lands, and thus the properties should be escheated to the Commonwealth for the municipalities’ benefit. The Hospital filed a special appearance challenging the court’s jurisdiction over the motion. The court denied the motion and the request to strike the special appearance, prompting the municipalities’ appeal.
ISSUE
1. Whether the Land Registration Court had jurisdiction to entertain the motion for adverse claim and escheat seeking to cancel final certificates of title.
2. Whether San Juan de Dios Hospital is a juridical person with capacity to own and register land.
RULING
1. The Land Registration Court correctly denied the motion for lack of jurisdiction. The motion sought a review and alteration of a final decree of registration, which is not permitted under Section 112 of Act No. 496 (the Land Registration Act). The final decree and titles had become incontrovertible under Section 38 of the same Act, beyond attack after one year from entry, absent fraud.
2. San Juan de Dios Hospital is a juridical person. It qualifies as a foundation of public interest under Article 35 of the Civil Code. Its juridical personality was also recognized by the State through Act No. 1724 , which ratified a settlement agreement involving the Hospital’s properties. This issue was already res judicata, having been conclusively settled in the original registration proceedings. The order denying the motion and upholding the special appearance was affirmed.
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