**Facts:**
The respondents Azucena Garcia, Elino Fajardo, and Teresa Malabanan filed a complaint on March 2, 1998, against petitioner Eland Philippines, Inc., for Quieting of Title with Writ of Preliminary Injunction. They claimed ownership of a parcel of land in Tagaytay City by virtue of possession under Commonwealth Act No. 141, as amended, for at least thirty years. They learned that a Decree No. N-217313 was issued to Eland Philippines, Inc., without their knowledge, which they argued amounted to fraud. Throughout the process, various motions and pleadings were filed, including a Motion to Dismiss by Eland, which was eventually denied; a Motion for Reconsideration was also denied. Eland was declared in default for not filing an answer but was later allowed to file an Answer Ad Cautelam. The trial moved forward with Eland’s motion to suspend proceedings due to a certiorari petition with the Court of Appeals, which was denied. Ultimately, the trial court granted the respondents’ Motion for Summary Judgment, declaring them as the rightful owners of the land, and nullifying Eland’s title.
**Issues:**
1. Was the respondents’ Motion for Summary Judgment compliant with the ten-day notice rule under Section 3, Rule 35 of the 1997 Rules of Civil Procedure?
2. Is a Motion for Summary Judgment appropriate in an action for Quieting of Title?
3. Were there genuine factual and triable issues in Civil Case No. TG-1784 that rendered summary judgment improper?
4. Did the trial court’s reliance on testimonies of respondents’ witnesses taken without Eland’s right to cross-examine and upon unadmitted documentary exhibits violate Eland’s right to due process?
5. Did the Court of Appeals err in upholding the trial court’s decision based on alleged falsified evidence?
6. Was Eland deprived of its right to due process by the trial court’s rendering of its summary judgment?
7. Does the trial court have jurisdiction to cancel Eland’s Original Certificate of Title in an action to quiet title?
**Court’s Decision:**
The Supreme Court granted Eland’s petition, reversing the Court of Appeals and the trial court’s decisions. It held that:
1. The ten-day notice rule was substantially complied with, but this does not necessarily validate the summary judgment.
2. A Motion for Summary Judgment can be proper in actions for quieting of title; however, in this case, it was found improper due to genuine issues needing full trial.
3. Genuine issues were present, making summary judgment improper.
4. The trial court’s reliance on certain evidences without proper cross-examination and admission violated procedural due process.
5. The court did not specifically address the alleged falsification of evidence but overturned the summary judgment on broader procedural grounds.
6. Eland was improperly deprived of a full trial, thereby impacting its due process rights.
7. The action for quieting of title was improperly used to contest the indefeasibility of a Torrens Title, which should have instead been addressed through an action for review based on fraud within the prescribed period.
**Doctrine:**
This case highlights the proper application of summary judgment in cases involving real property, the significance of upholding due process in trial procedures, and reaffirms the principle of the indefeasibility of the Torrens system of registration, which can only be challenged within specific bounds.
**Class Notes:**
– **Summary Judgment**: Appropriate when there are no genuine issues of material fact, allowing the court to rule as a matter of law. However, genuine issues for trial render summary judgment improper.
– **Due Process in Trial Procedures**: Parties must be given an opportunity to fully present their case, including the right to cross-examine witnesses and object to evidence.
– **Indefeasibility of the Torrens Title**: A Torrens title becomes indefeasible after one year from issuance, except in cases of fraud, emphasizing the stability and reliability of land registration under the Torrens system.
**Historical Background:**
The case underscores the tension between long-standing possession and formal land titling processes in the Philippines, particularly under the Torrens system which aims to settle and record land ownership definitively. The dispute highlights how complexities arise when historical possession confronts modern legal frameworks for land ownership, demonstrating the Philippine judiciary’s role in balancing these interests within the bounds of law and equity.
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