Case Digest (G.R. No. 231001)
Facts:
The case involves Constantino Y. Belizario (petitioner) as the main party against the Department of Environment and Natural Resources (DENR) and the Registry of Deeds of Nasugbu, Batangas (respondents). The events leading to this case began on May 12, 1960, when the Republic of the Philippines filed a complaint for annulment of titles against Ayala y Cia and several individuals, alleging that their titles illegally included portions of public domain lands. This case was docketed as Civil Case No. 373 in the Court of First Instance (CFI) of Batangas. The CFI ruled on June 2, 1962, declaring certain titles null and void and reverting the lands to public dominion. The Supreme Court affirmed this decision in 1965, confirming that the excess areas claimed by the Ayalas were indeed public lands.
Despite the Supreme Court's ruling, the execution of the annulment and reversion was delayed for over two decades due to various tactics employed by the Ayalas. In 2006, the Supreme ...
Case Digest (G.R. No. 231001)
Facts:
Origins of the Case
On May 12, 1960, the Republic of the Philippines filed a complaint against Ayala y Cia and others (the Ayalas) to annul certain titles. The Republic alleged that the titles improperly included portions of public domain lands and waters, expanding the original 9,652.583 hectares of Hacienda Calatagan to 12,000 hectares.
Court of First Instance (CFI) Decision
On June 2, 1962, the CFI declared Transfer Certificate of Title (TCT) No. T-9550 and other subdivision titles null and void, reverting the excess land to public dominion. This decision was affirmed by the Supreme Court in 1965, with no changes to the annulment and reversion aspects.
Execution of the CFI Decision
Despite the Supreme Court's 1965 decision, execution was delayed due to dilatory tactics. On November 16, 2006, the Supreme Court ordered the Regional Trial Court (RTC) to proceed with execution. The RTC directed the Department of Environment and Natural Resources (DENR) to conduct a relocation survey of the property to identify the excess land for reversion.
Petitioner’s Acquisition of the Land
On September 17, 1987, petitioner Constantino Belizario purchased a 24,961-square meter parcel of land in Calatagan, Batangas, from the Department of Agrarian Reform (DAR). TCT No. T-51621 was issued in his name.
Cancellation of Petitioner’s Title
On July 12, 2011, the RTC ordered the cancellation of petitioner’s TCT No. T-51621 after the DENR’s Technical Working Committee (TWC) determined it was a derivative title of TCT No. 722 and part of the excess land. Petitioner filed a motion to exclude his land, but the RTC denied it, finding insufficient evidence to prove his land was not part of the excess area.
Issue:
- Whether the CA erred in affirming the RTC’s cancellation of petitioner’s title despite petitioner not being a party to the reversion cases.
- Whether the Ayala y Cia and Zobel cases’ decisions bind petitioner.
- Whether the cancellation of petitioner’s title was valid despite the absence of an actual ground survey.
- Whether petitioner is an innocent purchaser for value of alienable and disposable land.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court affirmed the CA’s decision, holding that the RTC properly cancelled petitioner’s title as part of the execution of the CFI Decision. The Court emphasized the State’s authority to reclaim public lands and the binding effect of reversion suits on all derivative titles.