FACTS:

The case involves a disputed land in Antipolo, Rizal. In 1920, Fermin Lopez occupied and declared for tax purposes a public land in Makatubong, Barrio De la Paz, Antipolo, Rizal, with an area of 19 hectares, 48 ares, 88 centares. Fermin filed a homestead application for the land, but his application was not acted upon until his death in 1934. After Fermin's death, his eldest son Hermogenes Lopez worked on and improved the land. In 1936, Hermogenes inquired about the status of his father's application and was informed that it remained unacted upon. He then filed a homestead application in his own name and it was approved by the Bureau of Lands.

Hermogenes submitted the necessary requirements and a homestead patent was issued to him. Unbeknownst to Hermogenes, he was also awarded a homestead patent for the land. In 1956, Hermogenes executed an Extra-judicial Partition of the land with his brothers, and on September 12, 1958, they sold their share to Hermogenes. The following year, Hermogenes applied for registration of the property in his name but found that it had already been registered in the names of other individuals. In 1959, Hermogenes filed a complaint to annul the free patent and title, but it was dismissed. Another person, Ambrocio Aguilar, later filed a similar case and was declared the owner of the land.

Hermogenes died in 1982, and his heirs filed a complaint for cancellation of the deed of sale and reconveyance. The lower court declared the deed of sale null and void, and this decision was affirmed by the Court of Appeals. In 1985, the heirs of Hermogenes sold a portion of the land to respondent spouses Amurao. Subsequently, the heirs of Fermin and the heirs of Juan Lopez (Hermogenes' brothers) filed a case against the respondents, claiming co-ownership of the land and seeking reconveyance or payment of its value. Respondents, on the other hand, claimed to be the absolute owners of the land based on the homestead grant to Hermogenes.

The present case involves a dispute over a property among the parties. The case was initially dismissed due to the absence of the petitioners' counsel during the hearing, but the dismissal was reconsidered upon the motion of the petitioners' counsel. The case was then set for another hearing, but this time, the counsel for the respondent was absent. As a result, the petitioners were allowed to present their evidence ex-parte.

On June 25, 1987, the court rendered a decision in favor of the petitioners, ordering the division of the disputed lot among the four children of Fermin or their heirs. The respondents failed to appeal the decision but filed a petition for relief from judgment, claiming that accident or excusable negligence prevented them from attending the trial and that they have a good defense. The court granted the petition, set aside its previous decision, and ordered a pre-trial conference.

During the trial, the complainants entered into a compromise agreement with the heirs of Hermogenes, recognizing the latter's ownership and possession of the property. The court later rendered a partial decision approving the compromise agreement.

Subsequently, the court dismissed the complaint, declaring Hermogenes Lopez as the exclusive owner of the property. The court also ordered the plaintiffs to pay attorney's fees and costs. The petitioners appealed to the Court of Appeals, which affirmed the decision with modifications, deleting the award of attorney's fees. Dissatisfied, the petitioners filed the present action before the Supreme Court.

This case involves a petitioner who filed a petition to set aside a judgment rendered by the Regional Trial Court (RTC) on the grounds of fraud, accident, mistake, or excusable negligence. The petitioner alleges that he learned of the judgment and the need to set it aside within the prescribed period. The petition was accompanied by affidavits supporting the claims of fraud, accident, mistake, or excusable negligence.

ISSUES:

1. Whether the respondents were deprived of their right to a hearing due to accident.

2. Whether the respondents were able to show a good and substantial defense.

3. Whether Fermin acquired any vested rights as a homestead applicant over the property.

4. Whether Fermin's heirs inherited any property right from him.

5. Whether or not the deed and instruments at issue were void.

6. Whether or not respondents can be held guilty of estoppel by deed.

7. Whether or not there was sufficient evidence to support the claim that the application for homestead grant was filed by Hermogenes on behalf of all the heirs of Fermin.

8. Whether or not petitioners' attack on the authenticity and validity of the Deed of Absolute Sale is meritorious.

9. Whether or not petitioners are entitled to claim partition of the disputed property.

10. Whether or not petitioners are guilty of laches in enforcing their rights to the property.

RULING:

1. Yes, the respondents were deprived of their right to a hearing due to accident. Their counsel's absences during the hearings were excusable due to severe asthma attacks.

2. Yes, the respondents were able to show a good and substantial defense. They presented documents showing previous court decisions recognizing their absolute ownership and possession of the disputed property.

3. Fermin did not acquire any vested rights as a homestead applicant over the property because his application was neither approved nor denied by the Director of Lands. The Director has the discretion to approve or deny an application based on the requirements of the law.

4. Fermin's heirs did not inherit any property right from him because his application was never acted upon, thus preventing him from acquiring any vested rights over the land.

5. The Supreme Court denied the petition due to lack of merit. It reaffirmed the decision of the Court of Appeals, stating that the disputed deed and instruments were void. It also ruled that respondents cannot be held guilty of estoppel by deed. The Court further found that there was insufficient evidence to support the claim that the application for homestead grant was filed on behalf of all the heirs. The Court also rejected petitioner's attack on the authenticity and validity of the Deed of Absolute Sale. Moreover, the Court held that petitioners, who were not co-owners of the disputed property, cannot claim partition. Finally, the Court concluded that petitioners' argument regarding laches is irrelevant as there can be no delay in asserting a right where the right does not exist.

PRINCIPLES:

• The rules of procedure are not to be applied in a very strict and technical sense. They are used only to help secure and not override substantial justice.

• Homestead settlement is a mode of disposing public lands suitable for agricultural purposes, with the objective of providing a home for each citizen and inculcating feelings of independence.

• The requirements and procedures for obtaining a homestead patent under Act No. 2874 must be complied with, including the filing of an application, improvement and cultivation of the land, residency in the municipality, and presentation of final proof of compliance.

• Act No. 2874 requires the approval of the Director of Lands for a homestead application to be valid.

• The Director of Lands has the discretion to approve or deny an application based on the requirements of the law.

• A valid application is necessary for an applicant to acquire vested rights over the land.

• In case of the applicant's death, the widow or heirs may succeed in the rights and obligations over the land if the application has been duly approved.

• Estoppel does not operate to confer property rights where there are none.

• A person cannot be held guilty of estoppel by deed if the execution of the deed was merely to gain favors and does not constitute an admission of co-ownership.

• An applicant for a homestead grant must personally comply with the legal requirements and possess the necessary qualifications.

• Lack of co-ownership is a valid basis for rejecting a claim for partition.

• Laches is the negligence or omission to assert a right within a reasonable time and is an impediment to the enforcement of a right.