FACTS:

The case involves a petition for revival of judgment in a land registration case filed by respondent Lourdes Abiera Nillas. Nillas alleges that in 1941, the Court of First Instance (CFI) rendered a decision adjudicating several lots, including Lot No. 771, in favor of named oppositors. Nillas further claims that her parents eventually acquired Lot No. 771 in its entirety through various purchases. Despite these transfers and the continuous possession of the property by the Abierra spouses since the 1977 sale, no decree of registration has been issued for Lot No. 771. Nillas seeks the revival of the 1941 decision and the issuance of the corresponding decree of registration. The Office of the Solicitor General (OSG) argues that the right of action to revive judgment has prescribed, citing Article 1144 of the Civil Code and Section 6 of Rule 39 of the 1997 Rules of Civil Procedure. The OSG also relies on the cases of Shipside Inc. v. Court of Appeals and Heirs of Lopez v. De Castro to support its position.

The Republic of the Philippines filed a petition before the Supreme Court seeking the revival of a 1966 decision in a land registration case. The decision declared a parcel of land as public and not private land. The Republic argued that the decision should be revived and its decree of registration should be issued. The lower courts ruled in favor of the Republic and ordered the revival and issuance of the decree. However, the Office of the Solicitor General (OSG) filed a motion for reconsideration, claiming that the action was already barred by extinctive prescription and laches. The OSG cited two cases, Shipside Incorporated v. Court of Appeals and Heirs of Lopez v. Liboro, where the Court declared that extinctive prescription and laches were applicable. The OSG argued that the revival should have been filed within 10 years from the finality of the decision. However, the courts held that a different rule applies to land registration cases, which provides that neither laches nor the statute of limitations applies to a decision in a land registration case. The courts relied on the ruling in Sta. Ana v. Menla, which explained that after the ownership of a parcel of land has been proved and confirmed by judicial declaration, no further proceeding to enforce said ownership is necessary. This rule was reiterated and affirmed in subsequent cases such as Heirs of Cristobal Marcos v. De Banuvar, Rodil v. Benedicto, Vda. de Barroga v. Albano, Cacho v. Court of Appeals, and Paderes v. Court of Appeals. The courts held that the petition for revival was not barred by extinctive prescription and laches, and ordered the revival and issuance of the decree.

ISSUES:

1. Whether the rules on prescription and laches apply to land registration cases.

2. Whether Rule 39 of the 1997 Rules of Civil Procedure, which provides for the five-year prescriptive period for execution of judgments, is applicable to land registration cases.

3. Whether the failure of administrative authorities to issue the decree of registration affects the ownership of the prevailing party in a land registration case.

4. Whether or not a petition for revival of judgment is necessary for the implementation of a standing judgment or order from a land registration court.

5. Whether or not the doctrines of prescription and laches apply in the enforcement of a final decision in a land registration case.

6. Whether there was a ministerial duty on the part of the registration authorities to execute the judgment in favor of the petitioners.

7. Whether the right of ownership of the petitioners, as confirmed by the judgment in their favor, is indubitable.

8. Whether the doctrine in Sta. Ana still applies as a general precedent.

RULING:

1. The rules on prescription and laches do not apply to land registration cases.

2. Rule 39 of the 1997 Rules of Civil Procedure is not applicable to land registration cases.

3. The failure of administrative authorities to issue the decree of registration does not affect the ownership of the prevailing party in a land registration case.

4. In theory, there may be no need for a petition for revival of judgment since the duty to issue the decree of registration remains with the Land Registration Authority (LRA). If it is sufficiently established before the LRA that there is an authentic standing judgment or order from a land registration court that remains unimplemented, the issuance of the decree of registration should proceed without impediment. However, the court sees the practical value of necessitating judicial recourse if a significant number of years has passed since the promulgation of the unimplemented decision or order, as it would allow for a thorough examination of the veracity of the judgment or order sought to be effected.

5. The doctrines of prescription and laches may still apply in the enforcement of a final decision in a land registration case. Although prescription should not be a cause to bar the issuance of the decree of registration, a judicial evaluation would allow for a determination of causes other than prescription or laches that might preclude the issuance of the decree.

6. There was no ministerial duty on the part of the registration authorities to execute the judgment in favor of the petitioners since it would have disturbed a different final judgment that had already been executed and protected by a Torrens title.

7. The right of ownership of the petitioners is not indubitable considering the earlier decree of registration over the same property accorded to a different party.

8. The doctrine in Sta. Ana still applies as a general precedent, unless there is another ruling by a co-extensive or superior court that overturns or modifies the final judgment.

PRINCIPLES:

• The Sta. Ana doctrine affirms that the right of the applicant or a subsequent purchaser to ask for the issuance of a writ of possession of the land never prescribes.

• The intent of land registration proceedings is to establish ownership by a person of a parcel of land, and no further step is required to effectuate the decision once it becomes final.

• The Property Registration Decree does not contain any provision on execution of final judgments because there is no need for the prevailing party to apply for a writ of execution in order to obtain the title.

• Section 39 of the Property Registration Decree lays down the procedure between the rendition of the judgment and the issuance of the certificate of title, and imposes obligations on the land court, its clerk of court, and the Land Registration Commissioner to facilitate the issuance of the decree of registration. These obligations are ministerial on the officers charged with their performance.

• The failure of administrative authorities to issue the decree of registration or the failure of the applicant to follow up with said authorities does not affect the ownership of the prevailing party in a land registration case.

• The goal of the land registration system is the final and definitive determination of real property ownership, and imposing additional burdens on the owner after the judgment in a land registration case becomes final would frustrate this goal.

• The duty to issue the decree of registration remains with the Land Registration Authority (LRA).

• The court may require a judicial evaluation for the thorough examination of the veracity of the judgment or order sought to be effected.

• The doctrines of prescription and laches may still apply in the enforcement of a final decision in a land registration case.

• There is no ministerial duty to execute a judgment if it would disturb a different final judgment already protected by a Torrens title.

• A judgment confirming ownership rights is not indubitable if there is a previous decree of registration over the same property accorded to a different party.

• The doctrine in Sta. Ana applies as a general precedent unless it is overturned or modified by a co-extensive or superior court ruling.