Title
Republic vs. Malaba
Case
G.R. No. 169067
Decision Date
Oct 6, 2010
The Republic challenged Malabanans' land ownership, claiming it was public forest. Courts dismissed due to jurisdiction issues, but SC ruled appeal involved mixed questions of fact and law, remanding to CA.

Case Digest (G.R. No. 177505)
Expanded Legal Reasoning Model

Facts:

  • Parties and Property Details
    • Respondents Angelo B. Malabanan and Pablo B. Malabanan were the registered owners of a 405,000-square-meter parcel of land located in Talisay, Batangas.
    • The property was initially registered under Original Certificate of Title (OCT) No. 0-17421 and subsequently underwent cancellations and reissuances leading to Transfer Certificate of Title (TCT) No. T-9076 and ultimately TCT No. T-24268.
  • History of Land Registration and Title Cancellation
    • The original registration under OCT No. 0-17421 was effected on April 29, 1936 pursuant to Decree No. 589383, recorded in L.R.C. Record No. 50573.
    • The cancellation of OCT No. 0-17421 and its replacement with derivative titles occurred due to a later subdivision of the property, resulting in several lots with titles now in the names of either the Malabanans or Greenthumb Realty and Development Corporation.
  • Investigation and Filing of Complaint by the Petitioner
    • An investigation by the Department of Environment and Natural Resources (Region IV) revealed that the land covered by TCT No. T-24268 lay within an unclassified public forest per L.C. CM No. 10.
    • Based on this finding, the petitioner, Republic of the Philippines, filed a complaint for reversion and cancellation of title on March 30, 1998, initially docketed as Civil Case No. T-1055 and later re-docketed as Civil Case No. C-192.
  • Motion to Dismiss and Trial Court Proceedings
    • On May 5, 1998, the Malabanans filed a Motion to Dismiss, arguing that:
      • The complaint failed to state a valid cause of action.
      • The court lacked jurisdiction over the subject matter.
      • There was a violation of Section 7, Rule 8 of the 1997 Rules of Civil Procedure for the non-attachment of a copy of Decree No. 589383.
      • A similar complaint for reversion concerning the same parcels had already been dismissed by the court.
    • On December 11, 1998, the trial court dismissed the complaint, emphasizing that nullifying the original title would effectively annul the judgment of the Land Registration Court.
  • Appeals and Subsequent Orders
    • The petitioner filed a Notice of Appeal on January 5, 1999, challenging the trial court’s dismissal.
    • The Malabanans moved to deny due course and dismiss the appeal on the ground that the petitioner had erroneously adopted an improper mode of appeal, contending that the issue on jurisdiction was a pure question of law to be raised via a petition for review on certiorari.
    • On June 29, 1999, the trial court issued an Order dismissing the petitioner's appeal for lack of due course.
    • On February 29, 2000, the Court of Appeals (CA) reversed the trial court’s Order by ruling that the determination of whether an appeal may be dismissed on the basis of a pure question of law was within its discretion, thereby directing the trial court to give due course and transmit the records.
  • Arguments Presented on Appeal
    • The petitioner contended that:
      • The trial court erred in dismissing the complaint on jurisdictional grounds.
      • The order dismissing the complaint, which referenced previously decided cases upholding the Malabanans’ ownership, was flawed because the issue of whether such ownership had indeed been sustained was factual and required presentation of evidence.
    • The respondents maintained that, by filing a motion to dismiss, they had hypothetically admitted the truth of the facts in the petitioner’s complaint, hence no genuine factual dispute existed.
  • Court of Appeals’ Resolution and Issue on Proper Mode of Appeal
    • On July 20, 2005, the CA issued a Resolution dismissing the petitioner’s appeal under Section 2, Rule 50 of the 1997 Rules of Civil Procedure on the ground that the jurisdictional issue was a pure question of law, reviewable only by the Supreme Court through a petition for review on certiorari.
    • The sole issue before the Supreme Court was whether the CA committed a reversible error by dismissing the petitioner’s appeal for being the wrong mode to challenge the trial court’s dismissal.
  • Legal Framework and the Clarification on Appeal Modes
    • The case revisited the three modes of appeal from decisions of the Regional Trial Courts:
      • Ordinary appeal (or appeal by writ of error) under Rule 41 for questions of fact or mixed questions of fact and law.
      • Petition for review under Rule 42 applicable for judgments rendered in appellate jurisdiction.
      • Petition for review on certiorari under Rule 45 reserved exclusively for questions of pure law.
    • The Court elucidated the distinction between questions of law and questions of fact, determining that the factual inquiry regarding the Malabanans’ ownership involved evidentiary analysis, thus qualifying as a mixed issue.

Issues:

  • Jurisdiction and the Nature of the Issue
    • Whether the trial court had jurisdiction over the complaint for reversion and cancellation of title against the disputed property.
    • Whether the dismissal of the complaint by the trial court was proper given its conclusions regarding jurisdiction.
  • Appropriateness of the Mode of Appeal Chosen
    • Whether the petitioner's appeal, raised through an ordinary appeal under Rule 41, was appropriate despite the CA’s argument that the issue was purely one of law that should have been raised through a petition for review on certiorari.
  • Factual versus Legal Determination
    • Whether the question regarding the factual matter of the previously upheld ownership of the Malabanans required evidentiary presentation, thereby constituting a mixed question of fact and law rather than a pure question of law.
  • Impact of Previous Judicial Determinations
    • Whether the reference to previous cases that purportedly upheld the respondents’ ownership should bar the relief sought in the present complaint.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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