Case Digest (G.R. No. 236381)
Facts:
Republic of the Philippines v. Sixto Sundiam, et al., G.R. No. 236381, August 27, 2020, First Division, Caguioa, J., writing for the Court.The petitioner is the Republic of the Philippines (through the Office of the Solicitor General). The respondents are Sixto Sundiam, L & F Marketing, Inc., Jose Ma. Lopez, Rosendo D. Bondoc, Augusto F. Del Rosario, and Liberty Engineering Corporation, who are defendant-transferees of the disputed parcel.
In 1979 the Republic filed a Complaint for reversion before the Court of First Instance of Pampanga (CFI), alleging that a portion of Fort Stotsenberg Military Reservation (later Clark Air Force Base) had been surveyed and designated as Lot 727 and then subdivided, without proper approval, into parcels including Lot No. 727‑G (later Csd‑11198). One registered owner, Sixto Sundiam, secured registration for Lot No. 986 (OCT No. 80) and thereafter transferred the property through successive conveyances ultimately vesting in Liberty Engineering Corporation (TCT No. 34959). Discovering that the lot lay within the military reservation, the Republic sought reversion and cancellation of titles.
After summons, certain defendants requested a sketch plan showing the lot within the military reservation; by Order dated March 10, 1980 the CFI suspended the filing of their answers pending furnishing of that plan. The Republic did not comply and the CFI ordered the case archived on April 30, 1982. A later 1983 motion by the Republic to declare defendants in default was held in abeyance pending revival. About twenty‑four years later the Republic moved to revive the case and sought service by publication on Sundiam and L & F, Inc.
The revived proceedings reached the Regional Trial Court (RTC), Branch 56, Angeles City. Liberty Engineering Corporation moved to dismiss, asserting prescription, laches, and that the property had passed to innocent purchasers for value (IPVs). On October 7, 2015, the RTC granted the motion and dismissed the Republic’s Complaint; reconsideration was denied on March 15, 2016. The Republic appealed to the Court of Appeals (Seventh Division).
In CA‑G.R. CV No. 107773 the Court of Appeals, in a Decision dated December 19, 2017 (penned by Associate Justice Rodil V. Zalameda, with concurrences), affirmed the RTC, finding the Republic guilty of laches and applying ...(Subscriber-Only)
Issues:
- Did the Court of Appeals err as a matter of law in ruling that the Republic is guilty of estoppel by laches...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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