**Facts:**
1. On September 15, 1959, Hilario Ramirez and Valentina Bonifacio filed an application for registration of a parcel of rice land in Pamplona, Las Piñas, Rizal.
2. After notice and publication, no opposition to the application was registered, leading to an order of general default and the presentation of their evidences.
3. Petitioners claimed the acquisition of the land through purchase from Gregoria Pascual during the early American regime but lacked the contract of sale.
4. On January 30, 1960, the court issued a decree of registration, resulting in Original Certificate of Title No. 2273 being issued in the names of the petitioners.
5. On March 30, 1960, the respondents, private parties who were the legal heirs of Agapita Bonifacio, filed a petition to review the decree of registration, claiming fraud.
6. The private respondents alleged that Agapita Bonifacio acquired the property from Gregoria Pascual and that Pedro and other heirs continued possession through legal means like a mortgage. They also filed a separate Civil Case No. 272-R for recovery which was later dismissed, and the issue was merged with the registration proceedings.
7. Petitioners Ramirez and Bonifacio counterclaimed ownership based on deeds of sale found belatedly, which the court disregarded as spurious.
8. The trial court found in favor of the respondents, concluding fraud and ordering the reconveyance of property among the respondents and cancelling the petitioner’s title.
9. The Court of Appeals initially affirmed this but later temporarily reversed, and ultimately reinstated the trial court’s decision.
10. Petitioners Hilario Ramirez and Valentina Bonifacio brought the case to the Supreme Court via a petition for review on certiorari.
**Issues:**
1. Whether the Court of First Instance, acting as a Land Registration Court, had jurisdiction to review the decree of registration based on claims of reconveyance and fraud.
2. Whether Section 38 of Act No. 496 is applicable to land originally registration under Com. Act No. 141 as amended by Rep. Act No. 1942 for public agricultural lands.
3. Whether the Court of First Instance had the authority to vest title and order partition of the land among respondents despite the petitioners’ possession.
4. Whether private respondents had the legal capacity and qualification to be vested with the title of the land in question.
**Court’s Decision:**
– **Issue 1:** The Supreme Court upheld the appellate court’s findings that there were sufficient allegations of extrinsic fraud (misrepresentation, concealment, and positive falsehood) justifying the review and re-opening of the original proceedings under Section 38 of Act 496.
– **Issue 2:** The Supreme Court clarified that public lands, once registered under Act No. 496, are covered by its provisions, and thus, the lower court’s decree of registration could be reviewed for actual extrinsic fraud.
– **Issue 3:** The court affirmed that the Court of First Instance had authority to address ownership and possession disputes and order the reconveyance and partition of the land under the established antichresis agreement, rejecting the petitioner’s pleas.
– **Issue 4:** The court confirmed the respondents’ legal capacity and right to be recognized as the true owners, supported by stronger evidence of ownership through inheritance and continuous possession.
**Doctrine:**
1. **Extrinsic Fraud:** Fraud that affects the jurisdiction of the court or prevents a party from having their day in court justifies the re-opening of a final decree in land registration proceedings.
2. **Public Lands Registration:** Once alienated and registered, public lands fall under Act No. 496 and are subject to its provisions, including review of registration on grounds of fraud.
3. **Ownership under Antichresis:** The possession of land by an antichretic creditor does not confer ownership, and reacquisition of the land by the debtor requires the full payment of the debt.
**Class Notes:**
– **Elements of Fraud:** Emphasize on extrinsic fraud within legal proceedings which prevents fair presentation of cases.
– **Possession and Ownership:** Antichretic creditor retains possession but not ownership, per Article 540 Civil Code.
– **Re-opening Judgments:** Remedy available where there’s extrinsic fraud preventing proper adjudication.
– **Land Registration Law:** Once public land is registered, it is treated like private land under the Land Registration Act.
**Historical Background:**
During the early American regime, land ownership and title laws were reformed, often leading to disputes resolved through complex jurisprudence. Land titles and registration became key issues in Philippine legal history, reflecting the evolving doctrines surrounding ownership, possession, and rightful claims corrected through statutory law and jurisprudence, as evidenced in this case.
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