G.R. No. 187677 - Republic vs. Samson-Tatad

Petitioner: Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH).
Respondents: Hon. Rosa Samson-Tatad (Presiding Judge, RTC Branch 105, Quezon City), and private respondents Spouses William and Rebecca Genato.
Nature of Case: Petition for Review on Certiorari contesting CA Decision affirming RTC’s Order barring petitioner from presenting evidence to prove ownership over a property subject to expropriation.

On July 13, 2001, DPWH filed an expropriation complaint against several defendants, including respondents, for several parcels of land affected by construction of the EDSA-Quezon Avenue Flyover.
The Genatos own the subject property covered by TCT No. RT-11603, with an area of 460 square meters.
On June 14, 2002, DPWH received a report from Engr. Patrick Gatan asserting that the subject property was government-owned and the Genatos’ title was of dubious origin, overlapping government property.
Subsequently, on June 24, 2002, petitioner filed an amended complaint limiting the expropriation to the area confirmed as affected by the project, including the 460 square meters claimed by the Genatos as a conflicting claim.
On July 18, 2002, petitioner moved to have the subject property declared as of uncertain ownership or subject to conflicting claims.

RTC, by Order dated December 10, 2002, admitted the amended complaint, deferred the release of bank-deposited compensation (P18,400,000), and declared the property as subject to conflicting claims.
While petitioner tried to prove government ownership, respondents objected, arguing that presentation of evidence constituted a collateral attack on their Torrens title, barred under Section 48 of P.D. 1529.
On July 12, 2005, RTC issued an Order barring petitioner from presenting ownership evidence, citing prohibition against collateral attacks on Torrens title.
Motion for Reconsideration by petitioner was denied on November 17, 2005.

Respondents filed a motion for payment of just compensation and release of deposit in January 2006, still pending.
Petitioner filed a Petition for Certiorari with the Court of Appeals on February 9, 2006, seeking to reverse RTC Order and for a writ of preliminary injunction.
CA, on September 29, 2008, affirmed the RTC ruling applying Section 48 of P.D. 1529, dismissing the petition and denying the injunction.
Petitioner moved for reconsideration, denied on April 27, 2009.
This petition for review on certiorari followed, raising the question whether petitioner may be barred from presenting evidence against validity of respondents’ Torrens title.

Whether the petitioner (Republic of the Philippines, DPWH) can be barred from presenting evidence to challenge the validity of respondents’ Torrens title (TCT No. RT-11603) in an expropriation proceeding.