G.R. No. 217097 - Uy y Sayan vs. People

The consolidated cases involve a vast tract of land of approximately ninety-nine (99) hectares, which is purportedly government property belonging to the Republic of the Philippines.
The land had been previously adjudicated by a lower court (allegedly without proper jurisdiction) and later issued an original certificate of title along with transfer certificates of title to private individuals.
The validity of these decisions, including the classification of the land when the declarations (decrees of registration) were issued, is in dispute, raising questions about whether the land was in fact eligible for private disposition, particularly if it still fell within the inalienable forest zone.

Petitioners include the Republic of the Philippines represented by the Director of the Land Management Bureau; Firestone Ceramics, Inc.; and other private petitioners.
Respondents include the Court of Appeals, several private individuals, corporations such as Boomtown Development Corporation, and local government agencies like the Register of Deeds of Las Piñas, among others.
An intervenor, Alejandro B. Rey, was also present in the consolidated proceedings.

The Third Division of the Supreme Court had rendered a decision on September 2, 1999, denying the petitions and issuing motions for reconsideration that were later filed by both the government and private petitioners.
Petitioners subsequently filed separate Motions for Reconsideration as well as Motions to refer the cases to the Court En Banc.
Initially, a pleading entitled “FOR THE CONSIDERATION OF THE COURT EN BANC, EN CONSULTA” was presented on March 7, 2000; however, the Court opined that it was premature since the Third Division had not yet acted on the referral motions.
On March 8, 2000, the Third Division voted 4-1 to deny the motions for referral, thereby initially keeping the matter within the division.
Later, on March 14, 2000, the Court en banc deliberated “en consulta” and then voted 9-5 to accept the cases as en banc matters, invoking its residual power under paragraph 9 of the Resolution of November 18, 1993.

The central factual controversy involves whether the land in question was correctly classified at the time it was adjudicated and whether its subsequent transfer to private parties is valid.
Petitioners contend that the error in land classification affects the validity of the original decision and the resultant certificates of title.
The decision-making process is further complicated by conflicting interpretations of the case law (e.g., reference to Lemketkai Sons Milling, Inc. vs. CA and the Sumilao case) regarding judicial infallibility and the rectification of errors.
Additionally, dissenting opinions expressed concern over the Court en banc’s intervention, arguing that the majority did not present cogent reasons for overruling the Third Division’s initial vote and procedure, thus questioning the propriety of the en banc referral.

Whether the referral of the consolidated cases to the Court en banc was proper and justified given:

The error in the decision regarding the land’s classification, which has a direct impact on the validity of the certificates of title.
The pending motions for reconsideration and the necessity to resolve potentially erroneous judgments from the Third Division.

The extent and limits of the Supreme Court’s residual power under paragraph 9 of the Resolution dated November 18, 1993:

Whether “all other cases” deemed of sufficient importance to merit the attention of the full Court can be elevated to en banc despite an initial decision by a division.
The question of whether the property’s large area (99 hectares) and its alleged misclassification alone serve as a cogent rationale for en banc referral.

The proper role and deference to the decisions rendered by judicial divisions:

Whether the Court en banc, in assuming jurisdiction over the pending motions for reconsideration, undermines the competence of the Third Division.
The debate on whether a division—when its vote is decisive (i.e., obtaining the required majority)—should be overruled solely on the ground of perceived importance or error as argued by petitioners.

The appropriateness of the judicial procedure in resolving motions for reconsideration:

Whether the resolution of such motions should inherently remain with the division unless there is a demonstrated legal or factual error that warrants the full Court’s intervention.
The potential parallel drawn with the Sumilao case, where the procedural posture was different and the en banc referral was declined.