### Facts:
The origin of this case was a registration application filed by the petitioners on 30 August 1968 in the Court of First Instance of San Carlos City, Pangasinan, for several lots in Bayombong, Pangasinan. The applicants, heirs of Teodoro Y. Gomez, claimed ownership through inheritance from Consolacion M. Gomez and a Quitclaim executed by Luis Lopez. The trial court, upon no opposition, issued an order of general default and, eventually, a decision on 5 August 1981 in favor of the petitioners. This decision, uncontested within the reglementary period, directed the issuance of the corresponding decrees of registration.
On 11 July 1984, issues arose when respondent Silverio G. Perez reported that the lots in question were already covered by homestead patents issued in 1928 and 1929 and thus recommended setting aside the 5 August 1981 decision. Following hearings, the trial court, in its 25 March 1985 decision, voided its earlier decision and halted the issuance of decrees. Subsequent motions for reconsideration were denied, leading to a petition for certiorari and mandamus by the petitioners. The Court of Appeals dismissed the petition, a decision upheld upon the petitioners’ further appeal to the Supreme Court.
### Issues:
1. Did the trial court possess jurisdiction to void its final decision of 5 August 1981?
2. Was the duty to issue decrees of registration by the Acting Land Registration Commissioner and the Division Chief purely ministerial, and were they allowed to defy the final court ruling?
3. Is the Government of the Philippine Islands v. Abran case, determining the lands not as public, applicable as “law of the case” here?
### Court’s Decision:
1. **Jurisdiction of Trial Court**: The Court elucidated that the finality of land adjudication in cadastral or registration proceedings only attains incontrovertibility after one year from the entry of the final decree of registration. Hence, the trial court retains discretion to amend its decision if warranted by subsequent findings within this period.
2. **Duty to Issue Decrees**: The Court established that while the issuance of decrees by land registration officials is largely ministerial, these officials must act under the court’s direction and can refer doubts to it, making their act an extension of the court’s function. Thus, they did rightfully challenge the finality of the decision upon discovering conflicting homestead patents.
3. **“Law of the Case”**: The Supreme Court distinguished the current lots from those in the Abran case by noting that the lots currently in question were indeed covered by existing homestead patents, and thus not included in the land previously adjudicated to Consolacion M. Gomez.
### Doctrine:
The doctrine established is the distinctive nature of finality in land registration matters, wherein a decision does not become incontrovertible until after one year post-the issuance of the final registration decree, allowing room for necessary corrections based on newfound evidence.
### Class Notes:
– **Finality of Decision in Land Registration**: Unlike in ordinary civil actions, the adjudication of land in land registration or cadastral proceedings becomes final only after one year from the entry of the final decree of registration.
– **Role of Land Registration Officials**: These officials act under the court’s orders in issuing decrees of registration. Their actions are ministerial but allow discretion in referring uncertainties back to the court.
– **Homestead Patents and Land Registration**: Homestead patents, once registered under the Land Registration Act, gain the same indefeasibility and incontrovertibility as a Torrens title, precluding the land from being subject to further cadastral adjudication.
### Historical Background:
This case underscores the intricate balance between finality and fairness in cadastral and land registration proceedings. It highlights the judiciary’s efforts in rectifying potential oversights in the administration of justice, especially pertaining to land disputes that affect foundational property rights. The procedural path of this case from trial court to the Supreme Court and back illustrates the complexities inherent in land law and the importance of thorough examination at every legal juncture.
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