G.R. No. L-26112 - Republic vs. De los Angeles

This case is a special civil action for certiorari and mandamus involving petitioners—primarily the Republic of the Philippines and intervenor Miguel Tolentino, Sr.—against respondents which include Judge Jaime de los Angeles of the Court of First Instance of Batangas and private entities such as Ayala y Cia., Hacienda Calatagan, and Alfonso Zobel.
The dispute arose from controversies over possession of public lands, invalid titles, and the award of compensatory damages to Tolentino.

The lower court rendered a decision in Civil Case No. 373 (dated June 2, 1962) that awarded damages to Tolentino, which included language referring to “all the defendants.”
The Supreme Court, in G.R. No. L-20950 (May 31, 1965), affirmed the lower court’s decision with certain modifications, notably absolving some parties (e.g., the private respondents such as the Dizons) from liability for compensatory damages.
On October 4, 1971, the Court issued a resolution clarifying the ambiguity in the dispositive portion of the earlier judgment, emphasizing that phrases such as “all the defendants” were to be read in the context of the parties specifically enumerated, and that this clarification did not reopen or disturb the final judgment.

Petitioner Tolentino, Sr.—through his counsels—filed motions for reconsideration challenging the prior judgments and the clarification in the October 4, 1971 resolution.
The Republic, represented by the Solicitor General, also filed a motion for reconsideration; however, both motions largely attempted to inject extraneous issues beyond the scope of the special civil action.
Several supplemental pleadings were submitted, reiterating points that Tolentino contended would affect the award for damages and the liability of the private respondents.

The main factual controversy centers on the contested interpretation of the phrase “all the defendants” in the judgment awarding compensatory damages based on possession starting March 11, 1954, for Lot 360.
Questions of whether the private respondents (Dizons) are possessors in bad faith and therefore liable for damages—contrary to established findings—and whether Ayala, having divested its interest prior to Tolentino’s claim, should likewise be held liable.
The Government’s interest in enforcing the cancellation of void subdivision titles and the reversion of public land to the state.

Whether the Court should entertain issues that seek to delve into the merits of the underlying Civil Case No. 373, given that its judgment has already become final and executory.
Whether the motions for reconsideration improperly inject extraneous matters beyond the permitted scope of a special civil action for certiorari and mandamus.

Whether the ambiguous language in the dispositive portion—specifically the term “all the defendants”—should be construed to include or exclude certain private respondents (e.g., the Dizons, Ayala, and related parties).
Whether such an interpretation effectively reverses or disturbs the clear and final pronouncements made in the lower court decision and in the Supreme Court’s ruling in G.R. No. L-20950.

Whether petitioners have sufficiently established that the private respondents, though in possession, were possessors in bad faith and thus liable for the compensatory damages awarded to Tolentino.
Whether the award of damages calculated at P3,000 per year per hectare (accumulating to substantial sums) is factually and legally supported considering Tolentino’s lack of evidence of prior possession.

Whether the clarification in the October 4, 1971 resolution adversely affects the Government’s interest in enforcing the cancellation of the void titles and securing the reversion of usurped public lands and waters.
Whether the Government remains entitled to pursue its rights despite the motions that focus primarily on Tolentino’s private claim for damages.