& R.P. G.R.103727 & 106496, DEC.

18, 1996]
[NOTE: The official (1) Legal Brief for Titulo Prop. 4136, together with (2) Gen. Memo. to Gen. Phil. Public and the Intl. Community, (as it is perpetually bound by Treaty of Paris of 1898), including (3) 4 Affidavits of Adjudication, all appended to (4) Holograohic Will of Don Alejandro San Pedro, with (5) Court Order of Probate attached, had all been submitted to all concerned Reg. of Deeds where San Pedro Estate lays, per Sect. 13, Rule 76, Rules of Court, & Sect. 113 of Prop. Reg. Dec. (PD 1529); w/ copies furnished to: [Hon. President of the Philippines Natl. Bureau of Investn. (NBI) Hon. Supreme Court of the Repub. Philippines Natl.Police (PNP) Hon. Congress of the Philippines Armed Forces of the Phils. (AFP) incldng. DENR, BLM, NAMRIA, DOJ, LRA & Registry of Deeds]
SEC 142696sanpedrofoundation@yahoo.comTel. 839-701409207355333

Don Mariano E. San Pedro Foundation, Inc.

Sharing a legacy dedicated to Philippine progress and world understanding.

2. The said cases (G.R. Nos.103727 & 106496) were decided upon by Hon. Supreme Court sitting en banc. And the decision of Hon. Supreme Court on the said consolidated germane cases was unanimous. This was the longest running case in Phil. juris-diction covering many decades, & spanning diff. incumbencies of Supreme Court Justices, to decide. The decision is final, & arrived at after umpteenth motions for reconsiderations of the parties. 3. All previous San Pedro cases were considered. The Decision was made in full-length; & it is a rarest instance that Hon. Supreme Court presented (in full blown graphics) map of controversial estate i.e., to emphasize the vast land coverage of Titulo Prop. 4136. 4. What we have here is an enlightened activist Supreme Court; a legislatively intervening Supreme Court; a Supreme Court that is forward looking, that refused to be paralyzed & held hostage to societal evils lurking behind reign of greed & social cancer now gripping our land. Hon. Supreme Court is intuitive & expect-ant of this time of crisis to come, that people (thru Liga Filipina) shall call for change, and will need a peaceful instrument to act. 5. Because of this, La Liga Filipina shall not find it difficult to pursue its enlightened agenda of moral reform and peaceful social revolution in the Philippines. The Titulo Prop. 4136 is perfectly valid, and its vast lands are reserved to support and finance the nationalist struggle of La Liga Filipina to fight injus-tice, poverty, corruption, ignorance & superstition in the Phils. 6. Thus, the Hon. Supreme Court in the above said vital case confirmed and made it clear that the huge area of the vast lands under the

LEGAL BRIEF (THE POWER OF TRUTH)

IN CLARIFICATION OF THE EN BANC DECISION OF THE HON. SUPREME COURT IN THE FINAL SAN PEDRO CASES [G.R. Nos.103727 & 106496]

RE: TITULO DE PROPRIEDAD NO. 4136

[ON THE PERFECTION OF TITULO PROP. 4136 OF APRIL 25, 1894, AS INDEFEASIBLE & IMPRESCRIPTIBLE TITLE, THAT CAN NEITHER BE ANNULLED OR VOIDED, NOR SUBJECTED TO PRESCRIPTION OR LACHES,---I.E., IPSO FACTO, BY OPE-RATION OF THE LAW, & BY VIRTUE OF THE DISCOVERY OF 1971 & 1972 ORIG. CERTS. OF TITLE (OCTs) NOS. 0-5617 & 0-5797, UNDER LAND REG. CASES N-1861 & N-1876---AND NECESSARILY, IN THE LIGHT OF EN BANC DECISION OF HON. SUPREME COURT ON THE FF. CONSOLIDATED CASES: ESTATE OF LATE DON MARIANO SAN PEDRO VS. C.A., WITH PEDRO IGNACIO, ALIAS ENGRACIO SAN PEDRO, ET AL VS. C.A.

LEGAL BRIEF ON TITULO PROP. 4136, P.2

PREFATORY:
1. The operative and most authoritative Supreme Court case in the question of validity of the Titulo de Propriedad No. 4136 is the Estate of Late Don Mariano San Pedro y Esteban vs. Court of Appeals, and Pedro Ignacio, alias Engracio San Pedro, et al vs. Court of Appeals & Rep. of the Philippines, G.R. Nos.103727 & 106496, Dec.18, 1996.

controversial Titulo Prop. 4136 is 173,000 hectares. 7. Hon. Supreme Court always emphasized the huge extent of the lands of San Pedro estate. The Hon.Court said The heirs of late Mariano San Pedro laid claim and have been laying claim to the ownership of, against third persons and Government itself, a total land area of approx. 173,000 has. or 214,047 quiniones, LEGAL BRIEF ON TITULO PROP. 4136, P.3 7. The Hon. Supreme Court is not, here, maligning the true and legal San Pedro heirs; it in fact is impressing to the world the San Pedros most legal manner of claiming and owning the land, and it is by notorius and adverse claim and occupation of the land against the whole world, even as the Hon. Supreme Court, in effect, herein committed itself to acknowledge this fact, neces-sarily, by the power of its judicial notice (on the legal notorius claim of the San Pedros of the vast lands of Titulo Prop. 4136). 8. The operative law (Spanish Royal Decree) that granted land ownership at that time (April 25, 1894) was the Maura Law. This adjusts the land-grant of a latifundio w/ smaller area (4,700 has.), with a second larger land-grant of an encomienda (173,000 has. in the case of the San Pedro estate & its Titulo Prop. 4136). 9. The 2nd completion grant to Don Mariano San Pedro, allowed under Maura Law, for the encomienda of 173,000 has., was perfected under mortgage transactions (thru Spanish Mortgage Law) between Don Mariano and his friend Don Ignacio Conrado (Supremo of Rizal followers, Rizalistas, who would have accompanied Dr. Rizal in his proposed Philippine colonization of North Borneo). ( TP 4136 is now the only hope of La Liga Filipina to pursue its agenda of national

renaissance, of economic nationalism & national industrialization.) 10. Thus there is no longer any problem at all as to the identity of the Titulo Prop. 4136 (being examined). There is no laches, because the Hon. Supreme Court, no less, in its en banc Decision, acknow-ledges the notorious prosecution of the ownership interest of the estate of Don Mariano E. San Pedro by the claimant-heirs. 11. The matter of NBI Questioned Document Report is resolved by the presentation of the original NBI Questioned Document Report of NBI Expert Arturo Rotor in November 1968, right in the Land Reg. Cases N-1861 & N-1876, under Presiding Judge Emmanuel Munoz who examined the Spanish Title valid, so that he caused the issuance of Torrens Title to the San Pedro estate. The orig. NBI Questioned Doc. Report of Agent Rotor was the more valid basis of Land Reg. Court, under Judge Munoz, to approve TP 4136. 12. Insinuations then current that landgrabbing contractor-deve-lopers, together with Ortigass, have contributed to a billion peso fund stashed in several attach cases to bribe the Hon. Supreme Court Justices, while being plausible, is definitively belied and dis-proved by statesmanlike decision of Hon. Supreme Court in favor of the poor and the masses by causing the revalidation of TP 4136. LEGAL BRIEF ON TITULO PROP. 4136, P.4 17. Look at how easily the judgments of Hon. Supreme Court, sitting en banc in 1996 to finally dispose of San Pedros most fantastic land case, can get to allow the salutary principle of stare decisis and the values of equity and justice to overcome them, specially upon discovery of OCTs nos. 0-5617 & 0-5797 for TP 4136.

18. The 1st judgment is moot and academic. The validity of the TP 4136 is already res judicata. This came about upon discovery of OCTs 0-5617 & 0-5797, under LR Cases N-1861 & N-1876, which resulted in full compliance by TP 4136 with requirements of PD 892, and for its validity as Spanish Title. Therefore, the reestablished La Liga Filipina & the San Pedro Foundation, both institutions being affected with public interests, have all the right to utilize TP 4136 in their struggle to: 1) redeem the poor & oppressed, 2) upgrade human settlements, 3) establish food security, 4) pursue economic nationalism & national industrialization, 5) protect the environment, 6) fight injustice, poverty, ignorance, superstition & corruption in the government , as bidded in the Holographic Will of Don Alejandro. 19. The 2nd judgment, in light of revalidation of TP 4136, runs counter to nature of estate of deceased. Before its final execution in a Will or termination of its administration, it partakes of dynamic character, enabling it to grow by sound mngt., or a windfall may come from nowhere to enrich it more. Or, due to bad mngt., the estate is dissipated, but if theres showing of fraud or bad faith, the administrator, trustee or tenant, voluntary or not, he alone becomes responsible; & like in agency & as implied trustee, his gains in using the name and body of estate redound not to him but always to estate. 20. The 3rd judgment has also now become academic, because we already have our own independent Special Proceedings case in Pasig RTC, which is exclusive to Don Alejandro San Pedros Holo-graphic Will (with the Courts Order of Probate).

21. The 4th judgment refers to false heirs & fraudulent claimants of San Pedro estate. They can easily drop TP 4136 if it is be-coming hot for them to make their dirty money, and still exploit the estate by using other claptrap. But Don Alejandro, judicially confirmed true legal heir, had been painstakingly made different from all the rest of heirs by Judge Ofilada by declaring him alone as next of kin of Don Mariano. Don Alejandro was principled man, he would stand for integrity of TP 4136 & pursue familys tradition of sacrifice & altruism, & would always abide by the estates duty to contribute to Phil. progress, social justice & international understanding. LEGAL BRIEF ON TITULO PROP. 4136, P.5

on Spanish title, entitled Titulo de Prop. 4136 of April 25, 1894. The claim, according to San Pedro heirs, appears to cover lands in provinces of Nueva Ecija, Bul., Rizal, Laguna & Quezon; and such Metro Manila cities as Quezon, Caloocan, Pasay, Taguig, Pasig and Manila, thus affecting in general lands extending from Mal., Bul. to City Hall of Quezon and land area between Dingalan Bay in the north and Tayabas Bay in the south. 3. Hon. Supreme Court also made clear: The heirs or suc-cessors-in-interest of Don Mariano San Pedro are not without recourse. P.D. 892, xx, grants all holders of Spanish Titles the right to apply for registration of their lands under Act 496, or Land Reg. Act, within 6 months from effectivity of the Decree. Xxx The Hon. Supreme Court believed and said: We are in accord with the appellate courts holding xxx that since the Titulo was not registered under Act No. 496, otherwise known as the Land Registration Act, said Titulo is inferior to the registered titles of the private respondents Ocampo, Buhain and Dela Cruz (i.e. of the notorious OCT 614 and OCT 333). xxx This Court can only surmise that the reason for non-registration of the Titulo under Torrens system is lack of necessary documents to be presented to comply with P.D. 892. We do not discount the possibility that the Spanish title in question is not genuine, especially since its genuineness & due execution have not been proven. In both cases, petitioners-heirs were not able to present the original of Titulo Prop. 4136 nor a genuine copy thereof. LEGAL BRIEF ON TITULO PROP. 4136, P.6 4. But, what now if, contrary to the belief of Hon. Supreme Court, Titulo Prop. 4136 of April 25, 1894 had already been submitted to, and passed rigid

FACTS OF THE CASE:

1. The Hon. Supreme Court in its 1996 Decision en banc (on San Pedro estate) has confirmed and made it clear the huge area of vast lands under controversial Titulo Prop. 4136 is 173,000 has. (Pls. see decision in GR103727, Dec. 1996, with sketch plan of Titulo Prop. 4136.) It also made clear the two confusing dates (April 25, 1894 & April 29, 1894) involved in San Pedro controversy, and for purposes of its 1996 en banc Decision, Hon. Supreme Court affirmed April 25, 1894 as the correct & principal date, and (due to fact that petitioners-heirs, who are false heirs-claimants, werent able to pre-sent original of Titulo Prop. 4136 nor genuine copy thereof), Hon. Supreme Court thus made a grave declaration on Titulo Prop. 4136. 2. The Hon. Supreme Court further clarified: The heirs of the late Mariano San Pedro y Esteban laid claim & have been laying claim to ownership of, against 3rd persons and govt. itself, a total land area of approx. 173,000 has. or 214,047 quiniones, based

examination of Land Reg. Cases N1861 & N-1876? What if, indeed, there has already been such a Torrens title issued in favor of heirs of Don Mariano San Pedro necessarily after strict investigation of Titulo Prop. 4136 of April 25, 1894? Tears were shed by the helpless poor; many experienced feeling of deep remorse rising within their honest souls, when their last hope for justice had fled in Dec.1996. Will Justice forsake them again when at stake now is the precious honor they cherish above all else, when much that is left is the memory of those who tried to redeem the dignity of the poor and relentlessly fought for TP 4136? To goddess of Truth, we praise thee now with our gratitude, since our Motherland will be redeemed, cause weve found greater power of Truth of mysterious Titulo Prop. 4136! --the one hope of the poor, that was viciously maligned and ruthlessly assailed by combined forces of unscru-pulous rich and dark political powers that be. Yes! The Titulo Prop. 4136 has now gone back to life to save and give justice to the poor and oppressed and to help bring Philippines to Golden Age! 5. Indeed! There is really such Torrens Title (or Orig. Cert. of Title) that issued out of Titulo Prop. 4136 of April 25, 1894, and its not just one, but two! (Pls. see the orderly Land Reg. Cases No. N-1861 & N-1876. See also Partial Decision of Judge Emmanuel Munoz in Oct. 12, 1970 thereon. Pls. also see the OCTs 0-5617 & 0-5797 of Hon. Reg. of Deeds of Meycauayan, Bul. The Torrens Titles have been discovered only in 2001, and have become the object of complaint of Quieting of Title filed in Bulacan RTC against the false heirs, all 42 of

them with San Pedro surnames. The titles were hidden by false San Pedro heirs, seemingly because of coming confirmation of Don Alejandro San Pedro as next of kin and true legal heir of Don Mariano San Pedroi.e., with his most authentic Spanish docu-ments, discovered from 400 year-old church of Sta. Ana in Taguig. TP 4136 of April 25, 1894 had, indeed, been submitted in a Land Reg. Case under Act 496. Original of TP 4136 was necessa-rily shown, & examined (as indicated in the records), and found in order, so that in 1972, after due notice & hearing, the fact-finding and jurisdictional land reg. court, which is a court in rem, whose decision is final and against the whole world, (after lapse of a no. of years), issued forth a decree for issuance of Torrens Titles, namely, OCTs 0-5617 & 0-5797. TCTs also issued from OCTs, were transferred to innocent purchasers for value, and are now valid & perfect titles. LEGAL BRIEF ON TITULO PROP. 4136, P.7

issue would result into grave abuse of discretion that would just the same result into lack of jurisdiction. Hon. Supreme Court cant Order new trial to correct its mistake since doing so will result to double jeopardy against judicially confirmed next of kin and legal heir of Don Mariano; neither can it promulgate today, motu propio, a new judgment to correct the previous one where it erred because of stark absence of fair trial, & so would be lacking and be without due process. Indeed, the validity of TP 4136 of April 25, 1894 has become res judicata after it passed strict examination in Land Reg. Cases N-1861 & N1876, which are cases in rem that acquired notice & jurisdiction to whole world, and, as proof thereof, have resulted, the issuance of OCTs 05617 & 0-5797, together with equally perfect & valid TCTs that now passed to 3rd parties whore innocent purchasers for value. 3. Thus, how, Hon. Supreme Court speaks with voice of god, & is infallible, and cannot err. Everything, including its seeming mistake, is part of larger design for good of all and country. The most logical reading of motive in its said controversial 1996 en banc decision is that:--since lands under TP 4136 cant anymore revert to be public land (for lands under TP 4136 have since 1894 been owned as private lands, & were registered w/ Spanish Mortgage Law, & Treaty of Paris of 1898); and it s been a timehonored principle that whats been private land cant anymore become public, & since publicinterest San Pedro Found-ation has been prepared by judicially confirmed next of kin & true legal heir(ready) to assert peoples interest, & to avoid lands getting to fall to landgrabber-developers, (& to false heirs & fraudulent San Pedro claimants),-Hon. Supreme Court in a stroke of statesmanship, and of activist judicial wisdom, though not easily

understood & discernible to most, has forever wrote finish to celebrated San Pedro controversy. LEGAL BRIEF ON TITULO PROP. 4136, P.8 4. And so our faith in the Hon. Supreme Court has been strength-ened even more, but only after we have now fully understood the whole intent and ramifications of their 1996 en banc Decision on San Pedro case. Indeed, the Hon. Supreme Court dispenses justice to all, but ultimately sides with the disadvantaged people, and that, today, all rejoice because the people themselves will be served and benefited by dramatic resolution on ownership of vast tracks of land in question. On the side of judicially confirmed next of kin and true legal heirs, we know of their great sacrifices for the country, and they are always like today serving as mere instruments for greater cause and social justice. It is befitting to remember that Don Alejandro died a decent man; he was poor, but he served the country well, during World War II he was a volunteer guerrilla boy-runner under Gen. Walter Cushing Guerrilla Unit undertaking dangerous missions behind enemy lines at the age of 14 yrs.; Don Luis his father was an official Rizalista master who died in the war (1945) supervising the activities of their nationalist org.; Don Luis beautiful wife Dona Gorgonia Pascual, herself, suffered severe torture from Kempetais, because she would not reveal information, out of love for country and her family that went underground to fight the Japanese; Don Mariano himself, while being a Spanish subject, and a Mason, was raised in great liberal tradition; he was an industrious nobleman, as he in fact toiled his way to prominence, even meriting great land concessions from the grateful civil government of his time(then on the verged of being

ANALYSIS:
1. The Partial Decision of Judge E. Munoz that found Titulo Prop. 4136 to be in order,--as well as his issuance of judicial Decree for registration of the land thereof, and the final release of OCTs to said lands within Titulo Prop. 4136 of April 25, 1894,--is of absolute Judicial Notice in Phil. jurisdiction, specially to Hon. Supreme Court. 2. The question of validity of Titulo Prop. 4136 issued on April 25, 1894, after same was duly examined and found in order by the Hon. Land Reg. Court in in-rem proceedings, has become res judicata. Therefore, the said "en banc" Decision of the Hon. Supreme Court is in fact ultra vires on its part; and, hence, it acquired no juris-diction on Titulo Prop. 4136. Forcing the

overthrown by nescient Philippine rebellion). Don Mariano provided indispensable service in public works to the Spanish Crown and the Office of the Gov. Gen. of the Islands.

gesture with rewards, i.e. thru Hon. Judge Ofilada in Spec.Proc. 312-B. 3. Don Alejandro had his seeming rewards in fight against unscru-pulous land syndicates, & against false heirs & fraudulent claimants. Don Alejandros kinship and heirship with Don Mariano had been fully established & confirmed. He was made Special Adm., by Hon. Court, for true and legal estate of Don Mariano San Pedro. Don Alejandro was also granted authority to sell 169 has. within the adjudicated 445 has. San Pedro property in Norzagaray, Bul. And lastly, the SEC gave him full authority and reserved to him alone the use of the name Don Mariano E. San Pedro Foundation, Inc. as title of foundation. 4. In gratitude to Govt. & the people, when Don Alejandro prepared and personally wrote his holographic Will, he first secured enough part (20%) of San Pedro estate for the sake of his heirs & his illegi-timate & legitimate sisters in pro-indiviso equal shares; then he sought to inform all & sundry the need to vest San Pedro Foundation with enabling funds totalling 80% of whole San Pedro estate for sake of country, to redeem the poor, to advance S&T, modernize industries, upgrade human settlements, & to maintain countrys peace & order. 5. Final justice is poetic justice. And lastly, since syndicates & un-scrupulous malefactors of TP 4136 have greatly abused & exploited the name of our beloved Don Mariano, i.e. in amassing hundred thou-sand has., & in adversely occupying vast tracts of land, as inventoried in 1976 Order of Judge Fernandez, & in collection of double II plans in the name of Don Ignacio Conrado: its the stand of this represent-ation & of San Pedro Foundation, in regard to ownership of those lands, that: The law on agency holds! And

FURTHER ANALYSIS:
1. In the manner of seeking justice, Don Alejandro San Pedro was honest & above board in his petitions with Hon. Courts. Don Alejandro didnt have service of top law firms that entail high costs, he signed (w/ his lawyers his own petitions to govt., but hed original & authentic Spanish documents of heirship with Don Mariano, which he submitted to Hon. Courts,--and the truth won the day for him. (Pls. see Resolution en banc of Hon. Supreme Court, dated Feb. 28, 1989-directing Judge Carlos Ofilada himself to look for real heirs of Don Mariano--pls. see (jurisdictional & fact finding) Court Orders (dated Jan. 28,1996 & June13, 1997) of Judge Ofilada that determined & confirmed Don Alejandro San Pedro, Sr. as next of kin & true legal heir of Don Mariano San Pedro.) LEGAL BRIEF ON TITULO PROP. 4136, P.9 2. In regard to trial on appeal initiated by Pedro Ignacio, alias Engracio San Pedro, in Supreme Court, Don Alejandro naturally sided with Judge Fernandez & Govt. Its the truth presentation of genuine & authentic old Spanish documents (establishing his kinship with Don Mariano), which encouraged Hon. Supreme Court to destroy land & squatter syndicates (at that time led by, inter alia, alias Engracio San Pedro), and to write finish to San Pedro controversy. When Hon. Supreme Court finally issued its en banc Decision on the San Pedro estate, Don Alejandro lost no time in sending his Manipestasyon at Papuri to Hon. Supreme Court, and the Hon. Court returned the

we declare, that, howsoever much they have acquired & however far they have gone to exploit the name of Don Mariano, there will we come over to prosecute the interest of San Pedro estate--which is now owned & administered by San Pedro Foundation--necessarily, for Phil. progress & world understanding. LEGAL BRIEF ON TITULO PROP. 4136, P.10

CONNECTING ANALYSIS:
1. (Such is nature of Estate of the Deceased. Before its final exe-cution in a Will or termination of its administration, it partakes of dyna-mic character, enabling it to grow by sound mngt. (by succession of its administrators or tenants or their voluntary counterparts), or a windfall may come from nowhere to enrich it more. Or, due to bad mngt., the estate is dissipated, but if theres showing of fraud or bad faith, the administrator, trustee or tenant, voluntary or not, he alone becomes responsible; & like in agency & as implied trustee, his gains in using the name and body of estate redound not to him but always to estate, while he alone suffers, and shall be prosecuted for loss & damage he incurred & voluntarily committed.--Adapted from varied definitions given to estate of the deceased by Blacks Law Dictionary,) 2. In this connection: the 50,000 has. lands in Quezon, Rizal & Laguna couldnt have been validly acquired by Green Square Prop. Corp. from any supposed seller it transacted that only misrepresented San Pedro estate. (Pls. see G.R.139274 , Oct. 23, 2001, Quezon Prov., etc. vs. Hon. A. M. Marte, et al.) The original Tax Decl. issued in favor of heirs of Don Mariano San Pedro is, and remains, valid. 3. We must bear in mind that such Tax Decl. for 50,000 has. in Quezon, Rizal &

Laguna provinces is in name of Heirs of Don Mariano San Pedro. They are here alive, judicially confirmed as next of kin & true legal heirs of Don Mariano, & vested with legitimate judicial power to succeed the deceased and administer San Pedro estate. 4. Now that the provincial govt. of Quezon received mandate from Hon. Supreme Court in refusing to honor tax payments by Green Square, the real property rights (or original & legal right & privilege of ownership) thus remain with said true owners of the property, being the estate of Don Mariano E. San Pedro,--whose present devisee-owner and institutional judicial administrator is the Don Mariano E. San Pedro Foundation, Inc. 5. The Provincial Government of Quezon (in violation of the Constitutional right to property of the judicially confirmed next of kin and true legal heirs of Don Mariano San Pedro) cannot now invalidate the original Tax Declaration in the name of Heirs of Don Mariano E. San Pedro (now to be replaced by Don Alejandro P. San Pedrothe judicially confirmed next of kin and true legal heir of Don Mariano San Pedro), i.e. in the aftermath of the criminal sales transactions between said fraudulent parties. LEGAL BRIEF ON TITULO PROP. 4136, P.11 6. The fraudulent alleged-administrator, who is supposedly an officer of Court, but didnt have any legal mandate on record (or whose mandate has expired on date of salestransaction with Green Square, in Aug. 1996), together with Hon. Court who approved the transaction, must bear full responsibility of crim. act of large-scale estafa. (Legal San Pedro estate, & San Pedro Foundn.--being institutional jud. adm., is innocent & clean on this sales-transaction,

theyre victims here, & mustnt be visited by evil consequence of guilt of fraudulent parties.) 7. For its part, Green Square, company involved in realty business as it is, if its not a colluding co-conspirator in crim. transaction, must have exercised caution & always bear in mind the adage of caveat emptor, even as (particularly) because of its greed, it chose not to transact with rightful owner, Don Alejandro, who, at right time, had just been determined as next of kin & true legal heir of Don Mariano, in addition to being appointed by jurisdictional & factfinding Hon. Court as new Spl. Adm. of estate of Don Mariano San Pedro. (Pls. see Bul. RTC, Br. 15, SPC 312-B, Pres. Judge C. Ofilada, Court Order, dated Jan. 31, 1996, w/bond posted, & issued Letters of Spl.Adm. dated Apr.15,1996. Pls. compare said dates with Green Squares date of fraudulent-acqui-sitionAug.1996, allegedly from estate of Don Mariano San Pedro.)

after it passed strict exami-nation in LR Cases N1861 & N-1876, which are cases in rem that acquired notice & jurisdiction to whole world, &, as proof thereof, have resulted, issuance of OCTs 05617 & 0-5797, together w/ equally perfect & valid TCTs that now passed to 3rd parties whore innocent purchasers for value. 2. Indeed, the discovery of 1971/72 OCTs 0-5617 & 0-5797, under LR Cases N-1861 & N-1876, has resulted in full compliance by TP 4136 with the requirements of PD 892 for the validity of the Spanish Title. LEGAL BRIEF ON TITULO PROP. 4136, P.12 TP 4136 now remains valid Title for whole 173,000 has. (214,047 quiniones), covering lands in provs. of Nva.Ecija, Bul., Rizal, Laguna & Quezon; & M-Mla. cities as Quezon, Cal., Pasay, Pasig, Tagg., Pateros, Prnqe., Muntin., Mlbon., Mandlyng., Navts., Markna., S.J., Valnzla. & Mla., thus affecting in gen. lands extending from Mal., Bul. to City Hall of Quezon & land area between Dingalan Bay in the north & Tayabas Bay in the south. 3. Titulo Prop. 4136 of April 25, 1894, is hereby declared as inde-feasible, imprescriptible, & can neither be annulled or voided nor subjected to prescription or laches, til the end of time---i.e. despite (or by reason of) the Decision en banc of Hon. Supreme Court on San Pedro cases: GR Nos.103727 & 106496, Dec.18, 1996,---ipso facto, in light of the discovery of 1971/1972 Orig. Certs. of Titles (OCTs) No. 0-5617 and 0-5797, under Land Reg. Cases N-1861 & N-1876.

CONCLUSIONS:
1. The question of validity of TP 4136 of April 25, 1894, after same was duly examined & found in order by LR Court in in-rem proceed-ings, has become res judicata. Thus, said "en banc" Decision of Hon. Supreme Court is in fact ultra vires on its part; hence, it acquired no juris-diction on TP 4136. Forcing the issue results in grave abuse of discretion that just the same results into lack of jurisdiction. Hon. Supreme Court cant Order new trial to correct its mistake since doing so results to double jeopardy against jud. confirmed next of kin & true legal heirs of Don Mariano. Neither Hon. Sup. Court can promulgate today, motu propio, new judgment to correct previous one where it erred because of absence of fair trial, & will thus be lacking due process. To repeat, validity of TP 4136 of Ap. 25, 1894 becomes res judicata

RECOMMENDATIONS:

1. Theres no need to file any cases in court to revalidate Titulo Prop. 4136, because, for one, the Supreme Court en banc Decision has become final & executory. And it clearly lays in its en banc Decision the ground rule for validation of any Spanish title, thus: The heirs or

successors-in-interest of Mariano San Pedro are not without recourse. P.D. 892, xx, grants all holders of Spanish Titles the right to apply for registration of their lands under Act 496, or Land Reg. Act, within 6 months from effectivity of the Decree. 2. It suffices to say that said 1996 en banc Decision (on San Pedro estate) of Hon. Supreme Court has, ipso facto, officially clarified the 2 confusing version of Spanish titulo, TP 4136 of Apr. 25,1894 is real & valid Span. Title of San Pedro estate, & it covers (as affirmed by Hon. Supreme Court en banc) lands in provs. of Nva.Ecija, Bul., Rizal, Laguna & Quezon; & M.Mla. cities as Quez., Cal., Psay., Tag., Pasig & Mla., thus affecting in gen. lands extending from Mal., Bul. to Quez.City Hall of & land area bet. Dingalan Bay in the north & Tayabas Bay in the south. 3. With orig. (security) copy of OCTs 0-5617 & 05797, under LR Cases N-1861 & N-1876, officially kept & maintained in vault of Bul. RD, i.e. to prove compliance of TP 4138 to PD 892, San Pedro est., thru its owner & insttnl. jud.admin. (San Pedro Found.)--only now needs to execute its Affid. of Adjud. over TP 4136, appending same to holog. Will of Don Alejandro (w/ attached Court Order of Probate) to submit to concerned RDs where properties lay, & to publish the same for all the world to know & understand! By: Prof. A.D. San Pedro Chairman/Presiden t
No.38 Gurrero St., Taguig Citysanpedrofoundation@yahoo.comT- 8397014