Case Digest (G.R. No. 70853)
Facts:
The case involves Pablo Feliciano (respondent-appellant), who on January 22, 1970, filed a complaint before the Court of First Instance of Camarines Sur against the Republic of the Philippines, represented by the Land Authority, seeking recovery of ownership and possession of a parcel of land consisting of four lots totaling approximately 1,364.4177 hectares in Barangay Salvacion, Municipality of Tinambac, Camarines Sur. Feliciano claimed ownership of the land through a contract of sale dated May 31, 1952, and a deed of absolute sale dated October 30, 1954, both executed by Victor Gardiola, his predecessor-in-interest. Gardiola had acquired the land by purchase from the heirs of Francisco Abrazado whose title was evidenced by an "informacion posesoria," a possessory information under the Spanish mortgage law. Feliciano alleged he took possession of the land, introduced improvements, and caused it to be surveyed, with approval of the Director of Lands in 1954. He claim
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Case Digest (G.R. No. 70853)
Facts:
- Background and Nature of the Case
- On January 22, 1970, respondent Pablo Feliciano filed a complaint with the then Court of First Instance of Camarines Sur against the Republic of the Philippines, represented by the Land Authority, seeking recovery of ownership and possession of a parcel of land.
- The land consisted of four lots with an aggregate area of 1,364.4177 hectares, located in Barangay Salvacion, Tinambac, Camarines Sur.
- Feliciano alleged ownership through a Contract of Sale dated May 31, 1952, and a Deed of Absolute Sale dated October 30, 1954, from Victor Gardiola, who had acquired the property from the heirs of Francisco Abrazado.
- Title was purportedly evidenced by an "informacion posesoria". Feliciano claimed actual possession since purchase, improvements, and survey approval by the Director of Lands in 1954.
- President Ramon Magsaysay’s Proclamation No. 90 (November 1, 1954) reserved a tract of land for settlement under NARRA, which included the disputed land. Feliciano asserted his land should be excluded from the reservation as private property.
- He prayed that he be declared the rightful owner, his predecessor’s titular rights validated, and that awards given to settlers be nullified.
- Proceedings and Issues Raised
- The Republic of the Philippines, through the Land Authority, filed an answer raising defenses of lack of cause of action and prescription.
- On August 29, 1970, the trial court declared Lot No. 1 (701.9064 hectares) as private property of Feliciano, excluding it from the reservation, but declared Lots 2, 3, and 4 as reverted to public domain.
- 86 settlers and the Barrio Council of Pag-asay intervened, claiming possession for more than 20 years. The court reopened the case to allow evidence from intervenors.
- Intervenors failed to appear on the scheduled hearing, motion for postponement denied, and decision reaffirmed the 1970 ruling.
- Intervention motion and executions were subsequently addressed, with the court reopening the case to receive intervenors’ evidence after controverting procedural rulings.
- Intervenors filed a motion to dismiss citing non-suability of the State on August 31, 1970. The motion was opposed by Feliciano.
- On August 21, 1980, the trial court issued an order dismissing the complaint for lack of jurisdiction based on the non-suability of the State doctrine.
- Feliciano moved for reconsideration; the Solicitor General opposed, upholding dismissal for lack of consent to sue the Republic, and questioned validity of the informacion posesoria title.
- Upon denial of reconsideration, Feliciano filed a certiorari petition before the Intermediate Appellate Court (IAC), which reversed the dismissal on April 30, 1985, and remanded the case for further proceedings.
- The Republic of the Philippines brought the matter to the Supreme Court seeking review.
Issues:
- Whether the Republic of the Philippines, represented by the Land Authority, is liable to be sued for the recovery of ownership and possession of the land in question.
- Whether the dismissal of the complaint for lack of jurisdiction based on the non-suability of the State doctrine was proper.
- Whether the possessory information (informacion posesoria) held by Feliciano constitutes valid evidence of ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)