Case Digest (G.R. No. 215671)
Facts:
The case involves Alsons Development and Investment Corporation as the petitioner, and the Heirs of Romeo D. Confesor – Angelita, Geraldine, Romeo, Jr., Rowena, Juliane, Nicole, and Rubyanne, all surnamed Confesor – along with the Honorable Office of the President as respondents. This legal dispute arose from a petition for review on certiorari filed under Rule 45 of the Rules of Court, challenging the Decision dated December 13, 2013, of the Court of Appeals (CA) in CA-G.R. SP No. 117707. The decision affirmed the Office of the President’s (OP) rulings dated July 6, 2009, and December 20, 2010, which ordered the cancellation and revocation of Industrial Forest Plantation Management Agreement (IFPMA) No. 21, executed by the Department of Environment and Natural Resources (DENR) in favor of the petitioner.
The roots of the case trace back to January 15, 1996, when Alsons Development entered into a leasehold agreement with the DENR concerning a parcel of land spanning approximate
Case Digest (G.R. No. 215671)
Facts:
- The subject property is the basis of an Industrial Forest Plantation Management Agreement (IFPMA) No. 21 between the Department of Environment and Natural Resources (DENR) and Alsons Development and Investment Corporation (petitioner).
- The genesis of petitioner’s rights can be traced back to:
- Ordinary Pasture Permit (OPP) No. 1475 issued on June 23, 1953 to Magno Mateo over a pasture in Sitio Mabilis, Buayan, South Cotabato.
- Subsequent assignment by Mateo to Tuason Enterprises, Inc. on June 28, 1960, leading to the cancellation of Pasture Lease Agreement (PLA) No. 61 and the issuance of PLANo. 1715.
- Transfer of leasehold rights from Tuason Enterprises, Inc. to petitioner on March 24, 1964, with a new issuance of PLA No. 2476.
- The evolution of the forest management agreements:
- On June 26, 1992, petitioner and the DENR entered into Industrial Forest Management Agreement (IFMA) No. 21.
- The agreement was reissued on August 17, 1994, expanding its coverage area.
- On January 16, 1995, the IFMA was converted to IFPMA No. 21 with further expansion, culminating in its execution on January 15, 1996.
Background and Property History
- Protest by Respondents:
- On August 15, 2005, the Heirs of Romeo D. Confesor (respondents) filed a protest (RED Claim No. 008-06) before the DENR, Region 12 in Koronadal City.
- They contended that a significant portion of the land under IFPMA No. 21 was already covered by consolidated Original Certificate of Title (OCT) No. V-1344 (P-144) P-2252.
- Respondents argued that the DENR had no jurisdiction to enter into the lease agreement since the subject property was no longer classified as public land.
- Investigations and Conflicting Findings:
- The Land Registration Authority’s Task Force Titulong Malinis issued a report (August 2, 2004) alleging that OCT No. V-1344 was spurious based on a letter by Engr. Edmund Mateo, locating the plan (PSU-120055) in San Pablo City, Laguna.
- The Department of Justice later set aside the task force report (February 2, 2007), affirming the validity and existence of OCT No. V-1344 in the DENR records and confirming the property’s classification as alienable and disposable.
- The DENR on September 9, 2005, while confirming the genuineness of OCT No. V-1344 under PSU-120055, found that segregated certificates issued under Plan PSU-117171 to Romeo D. Confesor and others were fake.
- Administrative Proceedings:
- On August 22, 2005, the DENR, Region 12 dismissed respondents’ protest against IFPMA No. 21.
- The DENR Secretary, in a July 13, 2007 decision, upheld those findings and additionally found respondents guilty of laches for delay in asserting their ownership against petitioner’s predecessor.
- On appeal, the Office of the President (OP) in its July 6, 2009 Decision set aside the DENR’s determination by upholding the validity of OCT No. V-1344 and ruling that any doubts on its authenticity must be raised directly in a judicial proceeding; laches was also deemed inapplicable to Torrens-registered lands.
- Petitioner subsequently filed motions for reconsideration, leading to a reversal on October 12, 2009 (applying laches and non-compliance with Section 65 of CA 141 regarding permanent improvements), and then a re-reversal on December 20, 2010, reinstating the July 6, 2009 Decision.
- Judicial Developments:
- On January 19, 2011, petitioner filed a Petition for Review before the Court of Appeals (CA), seeking a status quo order due to the pendency of a related civil action (Civil Case No. 7711) for annulment of title and reversion.
- A subsequent motion for a temporary injunctive relief filed on January 24, 2011 was denied by the CA on March 14, 2011.
- Civil Case No. 7711 was dismissed on March 21, 2013 for procedural deficiencies.
- The CA then promulgated its decision on December 13, 2013 in CA-G.R. SP No. 117707, affirming the OP’s December 20, 2010 ruling, which:
- Determined the subject property as alienable and disposable.
- Upheld the authenticity of OCT No. V-1344 (P-144) P-2252.
- Limited the period for questioning the title under Section 38 of Act No. 496.
- Declared laches inapplicable given the indefeasible nature of Torrens registration.
- In light of these issues, petitioner argued that the proper disposition of IFPMA No. 21 was dependent solely on the outcome in the pending annulment and reversion case (Civil Case No. 8374) before the Regional Trial Court (RTC).
Emergence of the Controversy
- Petitioner’s Argument:
- The cancellation of IFPMA No. 21 should be deferred because its propriety is contingent on the pending RTC case which questions respondents’ title.
- Petitioner contended that the cancellation of the lease is premature and subject to the resolution of the title dispute that directly affects the government’s authority to lease or dispose of the property.
- Respondents’ Position:
- Respondents maintained that the DENR’s findings and the administrative decisions had already established a basis for canceling IFPMA No. 21.
- They argued that their claim of ownership through a valid title gave them the right to demand the cancellation of the lease agreement.
Interrelation of the Cases
Issue:
- Does the pending annulment of title and reversion case (Civil Case No. 8374) before the RTC, which directly challenges the validity of respondents’ title, constitute a prejudicial question that bars the cancellation of IFPMA No. 21?
- Is the outcome of the civil case determinative as to whether respondents legally possess the subject property and, thus, whether they have standing to demand the cancellation of IFPMA No. 21?
Prejudicial Question
- Whether the reliance on administrative findings regarding the authenticity of title by the DENR should directly effect the cancellation of IFPMA No. 21, or if such determinations must await the resolution of the pending RTC case attacking the title.
- Whether the issue of laches, as applied in earlier decisions, remains relevant given the Torrens system’s presumption of indefeasibility, and how that issue should impact the cancellation action.
Interrelation of Administrative and Judicial Proceedings
- Would proceeding with the cancellation of IFPMA No. 21 now lead to conflicting decisions if the RTC later rules against respondents’ title?
- How does the doctrine of prudence and economy in judicial proceedings apply to the interplay between these separate but interrelated disputes?
Avoidance of Conflicting Adjudications
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)