G.R. No. 224076 - Republic vs. Datuin

The Republic of the Philippines (petitioner), through the DENR Region IV-A Director and Office of the Solicitor General, filed on May 13, 2010, a complaint for cancellation of titles and reversion of six lots, covered by Original Certificates of Title (OCT) Nos. 921 to 926 and Transfer Certificates of Title (TCT) Nos. TP 1937, TP 1938, TP 1939, TP 1950, TP 1951, and TP 1952, against respondents Susan Datuin, Evelyn Dayot, Skylon Realty Corporation, Systematic Realty Inc., Parkland Realty & Development Corporation, Baguio Pines Tower Corporation, Goldland Realty Corporation, Good Harvest Realty Corporation, and the Register of Deeds of Nasugbu, Batangas.
The Republic alleged the lots were inalienable and could not be privately acquired pursuant to a final Supreme Court judgment in Republic of the Philippines v. Ayalay Cia/Hacienda Calatagan. It claimed fraud and irregularities in the issuance and transfer of titles from government fishpond lease lands to private respondents.

On July 27, 1987, Fishpond Lease Agreement No. 4718 for 298,688 sqm in Barrio Calumbayan, Calatagan, Batangas was issued to Prudencia V. Conlu, authorizing use for 25 years.
On August 19, 1987, the purported subdivision of this land into six lots was done under DENR Special Work Order (SWO) 04-001510-D, but in favor of six individuals other than Conlu.
Consequently, Batangas Register of Deeds issued six Original Certificates of Title (OCT) Nos. P-921 to P-926 to these individuals, including Susan Datuin.
On March 12, 1992, Transfer Certificates of Title were issued transferring all six lots to only two individuals, Susan Datuin and Evelyn Dayot.
In August 1996, Datuin sold the lots to six corporations which obtained corresponding titles (TCTs TP 1937–TP 1952).
DENR verifications in 2003 and 2006 established that the lots covered by SWO 04-001510-D overlapped exactly with the fishpond lease covered by FLA No. 4718 in the name of Conlu, and found no official file for SWO 04-001510-D.
The Supreme Court declared in Republic v. Ayalay Cia that Lot 360 (the same as the disputed lots) was inalienable and could not be privately owned.

Respondents Baguio Pines Tower Corporation and Systemic Realty Incorporated argued that as early as May 14, 1969, the lots were classified as alienable and disposable per Commonwealth Act No. 141, thus validly subject to private patent and title.
They traced back ownership history from predecessor Consolacion D. Degollacion’s Agricultural Sales Application in 1968, Bureau of Forestry certification in 1969 releasing the land as alienable and disposable, and DENR memoranda continuing processing of fishpond sales applications.
Respondents submitted a Request for Admission dated March 5, 2012 to the Republic, covering the genuineness and truth of documentary evidence supporting their claims.
After the Republic failed to respond, respondents moved for summary judgment in 2013 based on the doctrine of implied admission. Datuin and Dayot adopted this motion.

The RTC initially denied the motion for summary judgment on June 6, 2013, citing existence of genuine issues of fact concerning title validity and possible fraud in issuance.
Respondents filed a motion for reconsideration emphasizing the Republic’s failure to respond to the Request for Admission, thus the facts and evidentiary documents were deemed admitted under Rule 26, Section 2, of the Rules of Court.
The RTC granted the motion for reconsideration and simultaneously granted the motion for summary judgment in one Order dated September 3, 2013, dismissing the complaint and ruling in respondents’ favor.
The Republic's subsequent motion for reconsideration was denied on December 18, 2013.

The Republic filed a petition for certiorari under Rule 65 before the Court of Appeals, alleging grave abuse of discretion by the RTC for the simultaneous granting of reconsideration and summary judgment and violation of due process.
The Court of Appeals dismissed the petition on September 24, 2015, ruling that Rule 65 was not the proper remedy; the proper remedy was appeal under Rule 41.
The Republic’s motion for reconsideration with the Court of Appeals was denied on April 11, 2016.
The present petition challenges the dismissal and RTC orders.

Whether the Court of Appeals correctly dismissed the petition for certiorari as an improper remedy against the trial court’s summary judgment in respondents’ favor.
Whether the trial court correctly ruled that the Republic impliedly admitted the facts raised in respondents’ Request for Admission and properly granted summary judgment on that basis.