Facts:
On 13 July 2001,
the Republic of the Philippines, represented by the Department of Public Works and Highways (
DPWH), filed a
Complaint against several defendants, including
Spouses William and Rebecca Genato, for the
expropriation of parcels of land affected by the construction of the
EDSA–Quezon Avenue Flyover. The
Genatos were the registered owners of the subject property covered by
Transfer Certificate of Title (TCT) No. RT-11603 (383648), with an area of
460 square meters. During the proceedings, DPWH received a letter dated
14 June 2002 from Engr. Patrick B. Gatan reporting that the subject property was
government land and that the Genatos’ TCT was of
dubious origin and
fabrication because it allegedly encroached or overlapped with government property. Consequently, DPWH filed an
Amended Complaint on
24 June 2002, limiting the expropriation coverage to the portion shaded green in the sketch plan, including “
460 square meters” registered in the Genatos’ name. On
18 July 2002, DPWH filed a
Manifestation and Motion praying that the property be declared or considered of
uncertain ownership or
subject to conflicting claims. In an
Order dated 10 December 2002, the RTC admitted the amended complaint, deferred the release to the Genatos of the
₱18,400,000 deposited in the bank (equivalent to the zonal valuation), and declared that the property was
subject of conflicting claims. While DPWH presented evidence to show the property belonged to the government, the Genatos objected that DPWH was barred from presenting evidence because it would constitute a
collateral attack on the
validity of their Torrens title. After requiring memoranda, the RTC, in an
Order dated 12 July 2005, held that the
validity of the TCT could be raised only in an action expressly instituted for that purpose and barred DPWH from presenting evidence for violating
Section 48 of P. D. 1529. DPWH sought reconsideration, but the RTC denied it in an
Order dated 17 November 2005. On
4 January 2006, the Genatos filed a motion for
payment of just compensation amounting to
₱20,700,000 and for the release of the
₱18,400,000 deposited, which remained pending. DPWH then filed a
petition for certiorari before the CA with prayer for a temporary restraining order and/or writ of preliminary injunction on
9 February 2006. The CA dismissed the petition, affirming that the RTC properly applied
Section 48 because the property was covered by Torrens title under
P. D. 1529, and denied DPWH’s motion for reconsideration in
a resolution dated 27 April 2009. Hence, DPWH filed the present petition.
Issues:
Whether
DPWH, as condemnor, may be barred from presenting evidence that assails the
validity of the Genatos’
TCT No. RT-11603 (383648) in the expropriation proceeding.
Ruling:
Ratio:
Doctrine: