Case Digest (G.R. No. 240047)
Facts:
This is Authority of the Freeport Area of Bataan v. F.F. Cruz & Co., Inc., G.R. No. 240047, May 14, 2021, First Division, Gaerlan, J., writing for the Court. The dispute arises from land in Mariveles, Bataan originally reserved under Proclamation Nos. 899 and 939 (1971) and subsequently administered through a succession of agencies (FTZA → EPZA by P.D. No. 66 → PEZA by R.A. No. 7916 → Freeport Area of Bataan (FAB) and the Authority of the Freeport Area of Bataan (AFAB) by R.A. No. 9728). In transferring titles from PEZA to AFAB, AFAB discovered several parcels within the proclamation reservations that had Torrens titles issued in the name of F.F. Cruz & Company, Inc. (FFCCI) (derived from OCT No. 234 issued in 1972) (the Subject Properties).AFAB, through the Office of the Government Corporate Counsel, filed an Amended Complaint for Declaration of Nullity and Cancellation of Title against FFCCI and the Register of Deeds, alleging the Subject Properties were inalienable public domain reserved for the FAB and that the titles issued to FFCCI were null and void; it prayed for cancellation of OCT 234 and corresponding TCTs and reconveyance of possession to AFAB. FFCCI filed a Motion to Dismiss on multiple grounds (failure to state a cause of action, lack of clear territorial demarcation under R.A. No. 5490, claim that AFAB lacked authority to institute an expropriation-type action, protection of a purchaser in good faith under the Torrens system, res judicata, prescription and laches, and unpaid filing fees).
The Regional Trial Court (RTC), Branch 4, Mariveles, denied FFCCI's Motion to Dismiss in an Order dated December 21, 2015 and denied reconsideration in an Order dated March 30, 2016, holding AFAB’s Amended Complaint sufficiently alleged ultimate facts, that the matter involved inalienable lands of public domain (thus not an expropriation), and that defenses such as buyer-in-good-faith and prescription did not apply. FFCCI filed a petition for certiorari with the Court of Appeals (CA) which, in a Decision dated July 7, 2017, denied the petition and affirmed the RTC, but noted the RTC erred in hypothetically admitting the inalienable status of the Subject Properties — an error better addressed at trial.
FFCCI moved for reconsideration before the CA. The CA granted reconsideration in an Amended Decision dated June 7, 2018, reversed its prior ruling, and dismissed AFAB’s Amended Complaint on three principal grounds: (1) failure to state a cause of action; (2) RTC lacked jurisdiction because the complaint effectively sought annulment of OCT No. 234 (a matter proper for the CA); an...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in granting FFCCI’s Motion for Reconsideration and dismissing AFAB’s Amended Complaint on the ground that AFAB is not the real party in interest?
- Was the CA correct in ruling that the Amended Complaint fails to state a cause of action?
- Was the CA correct in treating the action as one for reversion that may be instituted only by the State through the Office of the Solicitor General (OSG)?
- If the action is one for reversion, are defenses such as prescription, laches, or res judicata available to FFCCI to bar the State’s claim?
- Assuming reversion, what is the proper proce...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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