Case Digest (G.R. No. 196888)
Facts:
Aurelia Narcise, Gloria A. Dela Cruz, Maritess O. Garcia, Philip Falcon, Enrico M. Vitug, Lynette C. Pontreras, Bonifacio Barrameda, Ramon S. Morada, Manuel G. Viola, Zenaida Lanuza, Cirilo G. Salto, Teodoro Del Rosario, Nancy G. Insigne, Melanie G. Viana, Romeo Ticsay, Amy J. Francisco, Marie J. Francisco, Zenaida Lanuza, Miguelito B. Martinez, Apolonio Santos, Marivic Tan, Jane Clor Dilema, Valentino Dilema, Jose L. Pangan, Antonia M. Mangelen, Imelda Manalastas, Teodorico N. Andrade, Aida L. Cruz, Manuel Yambot, Jaime Serdena, Ariel Palacios, Eve Bolneo, Libetine Modesto, Ma. Aileen Verde, Benny Ilagan, Michelle Romana, Danilo Villanueva, Leo Nalugon, Rossana Marasigan, Nelie Binay and Isabelita Mendoza v. Valbueco, Inc., G.R. No. 196888, July 19, 2017, Supreme Court Third Division, Tijam, J., writing for the Court.Petitioners are a long list of private individuals (collectively, the petitioners); Valbueco, Inc. is the respondent who originally filed the complaint. The litigation began when Valbueco, Inc. filed before the Regional Trial Court (RTC) of Balanga City, Branch 1, Civil Case No. 8144 on March 8, 2005, an action captioned as an Annulment of the Free Patents, Certificates of Title and Damages against the petitioners, the Department of Natural Resources (DENR), and the Register of Deeds of Bataan.
In its complaint, Valbueco, Inc. alleged continuous, peaceful, adverse possession of the subject lots since about 1970 and asserted ownership vis‑à‑vis titles and patents later issued in the names of the petitioners between 1977 and 1999. Rather than answering, petitioners filed several motions to dismiss alleging lack of cause of action, failure to state a cause of action, defective certification of non‑forum shopping, and prescription.
On December 7, 2006, the RTC (Judge Benjamin T. Vianzon) granted the motions to dismiss, characterizing the suit as an action for reversion under Commonwealth Act No. 141 and ruling that the Office of the Solicitor General (OSG) — not Valbueco — was the real party in interest; the RTC dismissed the complaint. The RTC denied Valbueco’s motion for reconsideration on March 7, 2007.
Valbueco appealed to the Court of Appeals (CA). In CA‑G.R. CV No. 89616, the CA reversed and set aside the RTC orders in a Decision dated December 21, 2010, holding that the complaint sufficiently alleged grounds to annul the free patents and titles and remanding the case for further proceedings. Petitioners’ motion for reconsideration before the CA was denied in a Resolution dated May 11, 2011.
Petitioners sought relief from the Supreme Court by filing a Petition for Review on C...(Subscriber-Only)
Issues:
- Whether the action filed by Valbueco, Inc. is an action for reversion or an action for annulment of free patents and certificates of title.
- Whether Valbueco, Inc. is the real party‑in‑interest in the action.
- Whether the action is barred...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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