G.R. No. 189434 - Marcos, Jr. vs. Republic

The case involves the annulment and reversion of improperly registered public lands originally part of Hacienda Calatagan, Batangas.
The Republic of the Philippines initiated proceedings by filing a complaint for annulment of titles against various private parties (including Ayala y Cia and related persons) before the Court of First Instance of Batangas in Civil Case No. 373.
It was alleged that the titles in question illegally included portions of the territorial waters and public lands due to an erroneous composite plan that expanded the area of Hacienda Calatagan from 9,652.583 hectares (as shown by TCT No. 722) to 12,000 hectares.

On June 2, 1962, the Court of First Instance declared the Transfer Certificate of Title (TCT) No. T-9550 and other subdivision titles null and void, ordering the reversion of the excess areas to the public domain.
The Supreme Court in Republic of the Philippines v. Ayala y Cia (G.R. No. L-20950, May 31, 1965) affirmed, with modifications, the annulment of these titles, clearly stating that the excess area—even if later subdivided and registered—did not confer private ownership over parts of the public domain.
Despite the finality of the 1965 decision, the execution of the annulment and reversion process was delayed for over two decades.
In subsequent proceedings, notably in Republic v. Delos Angeles (G.R. No. L-30420, March 25, 1988), the Supreme Court reiterated that all derivative titles issued over the excess areas were subject to cancellation and reversion to the State.

On September 17, 1987, Constantino Y. Belizario (petitioner) purchased a 24,961-square meter parcel from the Ministry of Agrarian Reform (DAR), resulting in the issuance of TCT No. T-51621 over the subject land.
Later, on June 28, 2011, the Regional Trial Court (RTC) of Balayan, Batangas, directed the cancellation of petitioner’s title on the ground that it was a derivative title of TCT No. 722, as determined by a Technical Working Committee (TWC) appointed by the Department of Environment and Natural Resources (DENR).

Petitioner objected by filing a Motion to Exclude — arguing that his title was not derived from TCT No. 722 — and subsequently presented evidence in court.
The RTC, however, denied his motion on November 16, 2011, finding insufficient evidence to prove that his land was not part of the excess area.
Petitioner also filed a motion for reconsideration on April 20, 2012, which was later denied on May 20, 2015.
His dissatisfaction with the RTC’s orders led him to file a Rule 65 certiorari petition before the Court of Appeals (CA).

The CA, in its Decision dated January 13, 2017, denied petitioner’s certiorari petition, affirming in toto the orders of the RTC.
Petitioner’s subsequent motion for reconsideration before the CA was also denied in a Resolution dated March 27, 2017.
The petitioner argued both procedural and substantive points, emphasizing his non-participation in the original reversion cases and his status as an innocent purchaser from DAR.

Whether the Court of Appeals committed reversible errors by not considering that:

The Republic should have filed a separate reversion suit against petitioner since he was never a party to the reversion cases (Republic v. Ayala y Cia and Republic v. Enrique Zobel) pending before the RTC in Balayan, Batangas.
The decision in the reversion cases (Civil Case Nos. 373 and 653) does not bind petitioner, who did not participate in those proceedings.
Cancellation of petitioner’s TCT No. T-51621 was executed without the benefit of an actual, ground-level survey.
As an innocent purchaser for value who acquired land from DAR, petitioner’s interest should be protected.