Case Digest (G.R. No. 127022)
Facts:
Firestone Ceramics, Inc., Boomtown Development Corporation, et al. v. Court of Appeals, G.R. Nos. 127022 and 127245, June 28, 2000, the Supreme Court En Banc, Purisima, J., writing for the Court.The consolidated petitions concern a vast tract of land of about ninety‑nine (99) hectares presumptively belonging to the Republic of the Philippines, which private parties claim through an adjudication and subsequent original and transfer certificates of title issued pursuant to a judgment allegedly rendered by a court without jurisdiction. The legal dispute turns on the classification of the land at the time of adjudication because that classification determines whether the property was alienable.
Proceedings began with the Third Division of the Supreme Court, which on September 2, 1999 promulgated a unanimous Decision denying the petitions. Thereafter both the Republic (through the Director, Land Management Bureau) and private petitioners (including Firestone Ceramics, Inc. and several private individuals) filed motions for reconsideration and separate motions to refer (transfer) the cases to the Court en banc. A pleading titled "For the Consideration of the Court En Banc, En Consulta" was presented to the Court.
On March 8, 2000 the Third Division voted 4–1 to deny the motions to refer the cases to the full Court. Nonetheless, Justice Fidel P. Purisima moved that the Court en banc take the cases out of the division and decide the pending motions for reconsideration. After an en consulta consideration on March 14, 2000, the Court en banc voted 9–5 to accept the cases for en banc resolution under paragraph 9 of the Court's November 18, 1993 Resolution (the so‑called residual power to treat as en banc any case that a majority of the Court deems of sufficient importance). The Court set the pending motions for reconsideration for oral argument on July 18, 2000 and directed notice to issue.
Several separate and dissenting opinions were filed. Justice Puno filed a separate opinion urging the Court to defer taking the case en banc until the Third Division completed oral arguments because the res judicata issue depends on factual development. Justice Gonzaga‑Reyes wrote a lengthy dissent arguing that the en banc should not rehear a division case against the will of the division and that paragraph 9 of the 1993 Resolution does not authorize such unilateral elevation. Justice Panganiban also dissented, contending the majority offered no cogent reason and that the Court's action was inconsistent with prior practice (notably the Sumilao and Fortich precedents). Several Justices concurred with the majority o...(Pro-only)
Issues:
- Did the Supreme Court en banc properly exercise its residual power under the Court's rules and resolutions to treat these consolidated cases as en banc matters despite the Third Division's 4–1 vote denying referral?
- Should the pending motions for reconsideration be decided by the Court en banc because the cases raise issues of sufficient importance (notably the classification of government land and the validity of titles issued under an allege...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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