Case Digest (G.R. No. 141019)
Case Digest (G.R. No. 141019)
Facts:
Jose Teofilo Mercado v. Valley Mountain Mines Exploration, Inc., G.R. Nos. 141019, 164281 and 185781, November 23, 2011, Supreme Court First Division, Villarama, Jr., J., writing for the Court.The controversy concerns five parcels in Barangay Sungay, Iruhin, Tagaytay City (Lots 4867, 7539, 7540, 7541 and 4831‑B) that had tax declarations in the names of the Heirs of Narciso Olimpiada and the Heirs of Juan Desengano. For nonpayment of real property taxes the City of Tagaytay auctioned the parcels on November 28, 1983; Valley Mountain Mines Exploration, Inc. (VMMEI) was the purchaser and received a Certificate of Sale. The heirs asserted continuous possession and ownership and sought to save the land.
In December 1984 Jose Teofilo T. Mercado paid sums to redeem the lots and obtained Certificates of Redemption; the City Treasurer refunded the purchase price to VMMEI. Mercado’s checks, however, were dishonored; the City Treasurer asked Mercado to replace the checks. In 1986 VMMEI offered to return the refunded bid price and thereafter the City Treasurer caused Final Bills of Sale to be executed in favor of VMMEI; tax declarations were cancelled and new ones issued in VMMEI’s name, which paid subsequent taxes.
Mercado claimed he had purchased the unregistered parcels from the heirs via deeds of sale and assignment and filed petitions for judicial confirmation of title under P.D. No. 1529 in the RTC of Tagaytay (LRC Case Nos. TG‑354, TG‑355, TG‑356) in September 1989. The Republic (through the Solicitor General), the heirs and VMMEI opposed; VMMEI also filed its own registration application (LRC Case No. TG‑383). The RTC issued a general default but heard evidence from the parties and, on November 26, 1992, rendered a decision confirming VMMEI’s ownership and granting registration in its favor, finding Mercado’s redemption defective and upholding VMMEI’s acquisition by returning the refunded bid price and procuring Final Bills of Sale.
Several groups of alleged heirs (the Carandang group, the Plateros, and the Olimpiada Heirs–Fabella group) pursued multiple motions to reopen, interventions, new suits (including annulment of auction sale and mandamus to correct tax declarations) and appeals. The Land Registration Authority (LRA) had earlier reported plan discrepancies and requested verification from DENR offices, recommending that the trial court hold decision in abeyance until those verifications and reports were received; nonetheless the RTC decided without waiting for those reports.
On appeal the Court of Appeals (CA) in CA‑G.R. CV No. 41164 and related dockets affirmed the RTC in a May 31, 1999 decision, dismissing the other petitions and denying the heirs’ efforts to intervene; the CA briefly archived proceedings at one point pending DENR resolution whether the land was forest/public land. Mercado’s motion for new trial based on alleged spurious Final Bills of Sale was initially granted then set aside by the CA. Mercado filed a petition for review (G.R. No. 141019). The Olimpiada heirs filed a certiorari petition (G.R. No. 164281) and a separate petition for review (G.R. No. 185781) from CA rulings dismissing their mandamus claim to have the tax declaration corrected.
The Supreme Court consolidated the three petitions. It examined (a) whether the land registration proceedings should have awaited LRA/DENR verifications and whether the trial court and CA erred in resolving ownership absent clear proof the lands are alienable and disposable, (b) whether Mercado’s redemption was valid and whether VMMEI’s acquisition was proper, and (c) procedural and remedial questions (properness of Rule 65 certiorari, availability of mandamus to compel correction of a tax declaration). The Court remanded G.R. No. 141019 to the RTC for further proceedings and directed the LRA and DENR to investigate and report; it dismissed the certiorari petition in G.R. No. 164281 and denied the petition for review in G.R. No. 185781.
Issues:
- Was the petition in G.R. No. 164281 properly filed under Rule 65 (certiorari) or was Rule 45 review the proper remedy?
- Did the trial court and the Court of Appeals commit reversible error by adjudicating the registration applications without awaiting the LRA/DENR verifications on the identity and registrability (alienable and disposable character) of the lands?
- Was Mercado’s asserted redemption effective and did VMMEI validly acquire title by repayment and Final Bills of Sale such that the RTC and CA correctly confirmed VMMEI’s registration?
- Was mandamus the proper remedy to compel the City Assessor to correct the 1974 tax declaration to add the words "et al." and thus recognize the petitioners as co‑owners?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)