Mendoza v.

CA
GR No. L-36637. July 14, 1978
Facts:
Generoso Mendoza filed an application for the registration of two parcels of
land, with a residential house thereon, situated in Bulacan. During the pendency of
the case, the same were sold to the respondent spouses Daniel Gole Cruz and
Dolores Mendoza, subject to the vendors' usufructuary rights. The instrument
embodying such sale was presented. The registration court rendered a decision
ordering the registration of the two parcels of land in the names of the vendees,
subject to the usufructuary rights of the vendors. Applicant-vendor, Generoso
Mendoza, filed a motion for the issuance of the decree. Thus, a decree was issued
confirming the title to the land of vendees and ordering the registration of the same
in their names.
Later on, petitioner filed an urgent petition for reconsideration praying that
the decision and the decree be set aside and the Title be cancelled, on the ground
that the vendees, the registered owners, had failed to pay the purchase price of the
lands.
The registration court set its decision. The registration court set aside its
decision. It held that it did not have jurisdiction to order registration in the names of
respondents who were not parties to the application for registration. The court then
ordered registration in the name of petitioner.
Respondents went to the Court of Appeals which reversed the order of the
trial court.
Issue:
Whether the registration court could not legally order the registration of the
land in the names of the vendees-respondents since they were neither the
applicants nor the oppositors in the registration case.
Held:
The Court disagreed.
Petitioner overlooks Section 29 of the Land Registration Act which expressly
authorizes the registration of the land subject matter of a registration proceeding in
the name of the buyer or of the person to whom the land has been conveyed by an
instrument executed during the interval of time between the filing of the application
for registration and the issuance of the decree of title.
The law does not require that the application for registration be amended by
substituting the "buyer" or the person to whom the property has been conveyed" for
the applicant. Neither does it require that the "buyer" or the "person to whom the
property has been conveyed" be a party to the case. He may thus be a total
stranger to the land registration proceedings. The only requirements of the law are:
(1) that the instrument be presented to the court by the interested party together
with a motion that the same be considered in relation with the application; and (2)

that prior notice be given to the parties to the case. And the peculiar facts and
circumstances obtaining in this case show that these requirements have been
complied with.