**Crisanta Guido-Enriquez vs. Alicia I. Victorino, et al.**
### Facts:
This detailed case traces a complex legal dispute originating from an Application for Registration of Title filed in February 1980 by Antonia Vda. De Victorino for a 10,603 square meter lot in Binangonan, Rizal. The Republic opposed the application, claiming the land belonged to the state. Subsequent investigations revealed the contested lot overlapped with land covered under TCT No. M-2102, registered to Antonia Guido, et al., and was also part of an ongoing legal dispute in the Guido Case. Despite a report indicating an error in the “coordinates” and affirming non-overlap, the resolution of Antonia Victorino’s application was initially held in abeyance pending the outcome of the Guido Case.
After the Supreme Court favored the reconstitution of TCT 23377 in the Guido Case, acknowledging the rights of bona fide occupants, Antonia Victorino’s heirs and Alicia Victorino pushed for the annotation of these rights and the issuance of a decree in favor of Alicia Victorino as the new owner. Despite procedural contentions and interventions by Crisanta Guido-Enriquez, the Regional Trial Court (RTC) of Pasig City issued orders facilitating this request.
Guido-Enriquez filed a motion for clarification and later a special civil action for certiorari with the Court of Appeals (CA), challenging these orders. The CA affirmed the RTC’s decisions with modifications, emphasizing the proper segregation and annotation in favor of Antonia Victorino’s lawful occupants. The Supreme Court, approached through a petition for review by Guido-Enriquez, upheld the CA’s rulings, emphasizing the finality of the August 15, 1988 decision and the appropriateness of the proceedings under which Antonia Victorino’s claim was established.
### Issues:
1. Whether the Court of Appeals erred in dismissing the petition for certiorari against the orders facilitating the annotation of the Victorino’s rights on TCT M-2102.
2. Whether the orders issued by the RTC Pasig City, which were affirmed by the CA, improperly altered the original 1988 decision granting Antonia Victorino’s application for registration.
3. The validity of the CA ruling that the proceedings under which Antonia Victorino’s rights were recognized were appropriate and in line with the Supreme Court guidance in related cases.
### Court’s Decision:
The Supreme Court denied the petition for review on certiorari, affirming the CA’s decision. It declared the objections against the RTC’s 1988 decision moot due to its finality, upheld the segregation of the lot on legal grounds, and found no defect in the CA’s acknowledgment of the proceedings as appropriate for validating Antonia Victorino’s rights. The court also addressed procedural queries regarding due process and participation, reinforcing the correctness of CA’s decisions under the circumstances.
### Doctrine:
The case reiterates the doctrine of immutability of judgment, emphasizing that a final and executory decision cannot be altered, except under specific, narrowly defined exceptions.
### Class Notes:
– **Finality of Judgment**: Once a court decision becomes final and executory, it is deemed immutable and unalterable, subject to limited exceptions such as clerical errors or void judgments.
– **Land Registration Proceedings**: These are in rem, meaning they are against the thing (property) itself rather than against individuals. Consequently, personal notice to claimants or interested parties is not always necessary; publication and notice sufficiency are determined based on the case specifics.
– **Doctrine of Laches**: This principle bars claims brought too late, emphasizing fairness and the discouragement of stale claims, especially in property disputes.
### Historical Background:
This case unfolds within the context of long-standing land registration disputes in the Philippines, juxtaposing claims under the Torrens system against traditional forms of land ownership and possession. The Supreme Court’s decision not only resolves the immediate controversy but also reinforces legal principles governing land registration, title validity, and the reconciliation of conflicting claims over land.
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