PEOPLE v CAINGLET

FACTS:
1. Wilfredo Cainglet was prosecuted for falsification of public and/or
official documents to cause the declaration of lots to be declared
as his private property.
Cainglet, in order to deceive the CFI in rendering a decision in
a Cadastral Case made the ff untruthful statements:
a. That he is the owner of the lot and buildings and
improvements thereon.
b. He is in possession for 3 years
c. The land was acquired by occupation and purchase from a
predecessor-in-interest who has been in possession thereof for
almost 30 years
d. No person having interest to the land
o When in fact the land is actually possessed and owned
by one Mindet Elon since the war
2. Cainglet filed a motion to quash contending that since the lands
were already declared private property, such judicial
pronouncements which ahs become final, allegedly runs counter
to the charge that accused falsely claimed said real estate to be
his own private properties.
3. Lower court granted the MTD
4. Hence, this appeal.

ISSUE: W/N the final judgment conferring the lots to Cainglet

bars his subsequent prosecution for falsely stating his answers
in the later Cadastral case.

HELD:
1. GR: It is fundamental and well-settled that a final judgment in a
cadastral proceedinga proceeding in remis binding and
conclusive upon the whole world, reason is that public policy and
public order demand not only that litigations must terminate at
some definite point but also that titles over lands under the
Torrens system should be given stability for on it greatly depends
the stability of the countrys economy.
2. XPN: Public policy also dictates that those unjustly deprived of
their rights over real property by reason of the operation of our
registration laws be afforded remedies.
o Thus, the aggrieved party may file a suit for reconveyance of
property or a personal action for recovery of damages against
the party who registered his property through fraud, or in case
of insolvency of the party who procured the registration
through fraud, an action against the Treasurer of the
Philippines for recovery of damages from the Assurance Fund.
 o Through these remedial proceedings, the law, while holding
registered titles inde-feasible, allows redress calculated to
prevent one from enriching himself at the expense of others.
Necessarily, without setting aside the decree of title, the
issues raised in the previous registration case are relitigated,
for purposes of reconveyance of said title or recovery of
damages.
3. In the same way, therefore, the State may criminally prosecute
for perjury the party who obtains registration through fraud, such
as by stating false assertions in the sworn answer required of
applicants in cadastral proceedings.
o Section 116 of the LRA applies to all and does not
distinguish between those who make false statements and
successfully procure registration by such statements, and
those whose statements were not given credence by the
land registration court.