**Facts**:
1. On 10 April 1997, respondent Lourdes Abiera Nillas filed a Petition for Revival of Judgment with the Regional Trial Court (RTC) of Dumaguete City.
2. The petition sought to revive a 17 July 1941 Decision Adicional rendered by the then Court of First Instance (CFI) of Negros Oriental in Expediente Cadastral No. 14 (El Director De Terrenos contra Esteban Abingayan y Otros), which adjudicated several lots, including Lot No. 771 of the Sibulan Cadastre, to Eugenia Calingacion and Engracia Calingacion.
3. Nillas claimed that her parents acquired Lot No. 771 through multiple transactions from 1975 to 1982. She herself acquired Lot No. 771 from her parents through a Deed of Quitclaim dated 30 June 1994.
4. Despite these transfers, no decree of registration had been issued over Lot No. 771 since the 1941 CFI decision.
5. The RTC conducted a trial on the merits, and on 26 April 2000, it rendered a decision to revive the 1941 judgment and directed the Land Registration Authority (LRA) to issue the corresponding decree of confirmation and registration.
6. The Office of the Solicitor General (OSG) appealed to the Court of Appeals (CA), which denied the appeal on 24 July 2003.
7. The OSG contended that the action to revive the judgment had prescribed and should be barred by laches, and argued that Nillas should have first requested the issuance of the registration decree from the LRA.
**Issues**:
1. **Applicability of Prescription and Laches**:
– Whether prescription (a period within which a legal action must be brought) or laches (a delay in asserting a right) may bar a petition to revive a judgment in a land registration case.
2. **Necessity of Prior Request to LRA**:
– Whether Nillas was required to first request the issuance of the decree of registration from the LRA before seeking judicial intervention.
3. **Res Judicata Applicability**:
– Whether the 1941 decision constituted res judicata (a matter already judged) to bar subsequent attacks on the adjudicates’ title over the subject property.
**Court’s Decision**:
1. **On Prescription and Laches**:
– The Supreme Court affirmed the doctrine that neither prescription nor laches applies to a decision in a land registration case. The Court reiterated from Sta. Ana v. Menla that decisions in land registration cases are declaratory and do not need to be enforced in the same manner as judgments in civil actions.
– The Court found no error in the CA’s decision that special proceedings, including land registration cases, are not subject to the prescriptive periods for enforcing judgments by motion or action.
2. **On Prior Request to LRA**:
– The Court held that there is no statutory requirement in the Property Registration Decree (PD No. 1529) for the prevailing party to first request the issuance of the decree of registration from the LRA. Instead, the duty to issue the decree is ministerial on the part of the LRA once the judgment becomes final.
3. **On Res Judicata**:
– The Court dismissed the OSG’s contention regarding res judicata, stating that the 1941 Decision remained susceptible to effectuation by the according decree of registration despite delays in its enforcement and procedural lapses by the LRA.
**Doctrine**:
1. **Non-Applicability of Prescription or Laches**: The principles of prescription and laches do not bar the enforcement of judgments in land registration cases (Sta. Ana v. Menla).
2. **Ministerial Duty to Issue Decree**: Upon finality of the decision in a land registration case, there is a ministerial duty on the part of the land registration court and the Land Registration Authority to issue the decree of registration (PD No. 1529).
**Class Notes**:
– **Prescription and Laches**: These do not apply to land registration cases (Sta. Ana doctrine).
– **Special Proceedings**: Distinct from civil actions, these establish facts or statuses, not enforce rights against adversaries (Primordial in land registration).
– **PD No. 1529, Sec. 39**: Directs the issuance of decree and certificate of title after the court’s judgment is final.
– **Ministerial Duty**: Obligations on court and LRA; judicial intervention unnecessary unless practical difficulties warrant it.
**Historical Background**:
– The case illustrates wartime disruption’s long-term legal impacts; the 1941 Decision coincided with the Japanese invasion of the Philippines.
– Reflects the evolving procedural mechanisms in land registration from pre-war cadastral courts to the modern government framework under the Property Registration Decree.
– Emphasizes the Philippines’ legal system’s aim to secure land ownership and address administrative failures post-independence and post-war reconstruction.
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