Title
Belizario vs. Department of Environment and Natural Resources
Case
G.R. No. 231001
Decision Date
Mar 24, 2021
A petitioner's land title was canceled as it derived from a void title in a reversion case, affirming the State's authority to reclaim public domain lands despite claims of being an innocent purchaser.
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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:

  1. Whether the CA erred in affirming the RTC’s cancellation of petitioner’s title despite petitioner not being a party to the reversion cases.
  2. Whether the Ayala y Cia and Zobel cases’ decisions bind petitioner.
  3. Whether the cancellation of petitioner’s title was valid despite the absence of an actual ground survey.
  4. 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.


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