Case Digest (G.R. No. 237663) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Heirs of Ma. Teresita A. Bernabe and Cooperative Rural Bank of Bulacan, G.R. No. 237663 (Oct. 6, 2020), the Republic, through the Office of the Solicitor General (OSG), filed on August 23, 2004 a Complaint for Cancellation of Title and Reversion against Ma. Teresita E. Bernabe. It alleged that Lot No. 965, formerly part of Lot No. 727 of the 1908 Camp Stotsenburg Military Reservation (now Clark Air Base), was never alienable or disposable public domain. Title had passed from Francisco Garcia (OCT No. 83, 1968) to Nicanor Romero (TCT No. 21685) and thereafter to Bernabe (TCT No. 107736). A Bureau of Lands survey confirmed the land remained military reservation, rendering the original Torrens registration void. In January 2006 Bernabe’s heirs mortgaged the property to Cooperative Rural Bank of Bulacan (CRBB). The Republic amended its complaint in December 2011 and again in March 2012 to implead CRBB. CRBB moved to dismiss, arguing (a) lack of real Case Digest (G.R. No. 237663) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Republic of the Philippines (petitioner), represented by the Office of the Solicitor General (OSG), filed a Petition for Review under Rule 45 before the Supreme Court.
- Respondents: Heirs of Ma. Teresita A. Bernabe (registered owner) and Cooperative Rural Bank of Bulacan (CRBB), mortgagee and later placed under PDIC receivership.
- At the trial court (RTC, Branch 59, Angeles City), the Republic’s Second Amended Complaint for Cancellation of Title and Reversion was dismissed on CRBB’s Motion to Dismiss.
- The Court of Appeals (CA) affirmed the dismissal in CA-G.R. CV No. 104631, holding that (a) the Republic lacked standing as real party in interest, and (b) the Verification and Certification Against Forum Shopping (VCAFS) was defective.
- Land and Title History
- July 31, 1908 Proclamation by Governor General Smith reserved parcels in Pampanga for military use (Fort Stotsenburg/Clark Air Base).
- Lot No. 727 (Psd-5278) was surveyed and awarded to Jose Henson, subdivided into Lots 727-A to 727-G; Lot 727-G further subdivided into 63 portions (Survey Plan Csd-11198).
- One portion (Lot 965, formerly Lot 42 of Csd-11198) was fraudulently registered by Francisco Garcia in 1968 (OCT No. 83); sold to Nicanor Romero (TCT No. 21685) and thereafter to Bernabe (TCT No. 107736).
- Bureau of Lands investigation found the subject property within the military reservation, uncultivated, with no monuments — cadastral registration was void for fraud.
- Reversion Proceedings and Pleadings
- December 5, 2011: Republic filed Amended Complaint adding CRBB; March 5, 2012: Second Amended Complaint.
- CRBB moved to dismiss, arguing (a) improper party (should be Director of Lands or BCDA), (b) no BCDA authorization for VCAFS signatory, and (c) need to proceed in Liquidation Court.
- OSG opposed, invoking State’s imprescriptibility and jura regalia, and asserting its exclusive power to file reversion suits.
- RTC and CA Decisions
- May 13, 2014 RTC Resolution granted CRBB’s motion, dismissed complaint without prejudice to BCDA filing with valid VCAFS.
- CA Decision (February 21, 2018) affirmed: (a) BCDA, not Republic, is real party in interest under Proclamation 163 (1993) and R.A. 7227; (b) VCAFS signed by BCDA President lacked board authorization; (c) dismissed appeal.
Issues:
- Whether the CA erred in holding that the Republic is not the real party in interest and cannot invoke imprescriptibility.
- Whether the CA erred in ruling that the VCAFS was defective for lack of valid BCDA board authorization.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)