G.R. No. 201821 - Malaba vs. Republic

The Republic of the Philippines, through the Office of the Solicitor General, initiated an action for the reversion of land and cancellation of title against Angelo B. Malabanan, Pablo B. Malabanan (petitioner), and Greenthumb Realty and Development Corporation.
The subject properties were covered by Transfer Certificate of Title (TCT) No. T-24268, purportedly derived from an Original Certificate of Title (OCT) No. 0-17421, which was allegedly issued pursuant to Decree No. 589383 in the Land Registration Court (LRC) Record No. 50573.
The Republic contended that no valid judgment existed in LRC Record No. 50573 and that the land, situated within the unclassified public forest of Batangas, was part of the public domain and therefore inalienable.

The action was initially filed as Civil Case No. C-192 in the Regional Trial Court (RTC), Branch 83 in Tanauan, Batangas.
The petitioner moved to dismiss the case, arguing that the action effectively sought the annulment of a non-existent LRC judgment—a matter that fell within the exclusive jurisdiction of the Court of Appeals (CA) under Section 9(2) of Batas Pambansa Blg. 129.
The RTC, on December 11, 1998, granted the motion to dismiss, basing its ruling on jurisdictional grounds and the fact that similar reversion complaints had previously been dismissed due to lack of jurisdiction.

The Republic filed a notice of appeal against the RTC’s dismissal and later, the CA reversed the dismissal on May 27, 2011.
The CA set aside the RTC’s December 11, 1998 order and remanded the case back to the RTC with instructions to proceed with a trial on the merits, including the filing of responsive pleadings by the defendants-appellees.
The petitioner then challenged the CA ruling, asserting that the appeal was improperly considered since it involved a question of law regarding jurisdiction and should have been resolved by certiorari.

The complaint alleged that TCT No. T-24268 had emanated from OCT No. 0-17421, where the basis for issuance was dubious due to the absence of any searchable judgment in LRC Record No. 50573.
It further noted that the land was subdivided into various lots, with some titles transferred to Greenthumb Realty and Development Corporation while others remained in the names of the Malabanans.
The relief sought was specific to the cancellation of OCT No. 0-17421 and the reversion of the property to the Republic, asserting that the property was part of the unclassified public forest and should not be privately owned.

Whether Civil Case No. C-192 is properly classified as an action for cancellation of title and reversion of land to the public domain, rather than an action for annulment of a Land Registration Court judgment.
Whether the RTC has original and exclusive jurisdiction over such reversion suits when the subject matter involves real property disputes under the Public Land Act.

Whether the petitioner’s contention that the case should instead be treated as one seeking annulment of judgment (and thus falling under the purview of the CA under Rule 47) is tenable.
Whether the prior rulings cited by the petitioner concerning annulment of judgments are relevant to an action that targets the title itself.

Whether the RTC was correct in declining to dismiss the appeal and in remanding the case for trial to resolve factual issues regarding the alleged public domain status of the property.
Whether the evidentiary allegations involving the absence of a valid judgment and the classification of the land necessitate a full trial on the merits.