Case Digest (G.R. No. L-15654)
Facts:
This case involves the Republic of the Philippines, represented by the Regional Executive Director (RED) of the Department of Environment and Natural Resources (DENR), Regional Office No. III, as petitioner, versus Tanduay Lumber, Inc., Verbo Realty and Development Corp., several spouses and individuals, and the Register of Deeds of Bulacan as respondents. The controversy centers on land originally covered by Free Patent No. (III-12) 17306, issued on May 20, 1987, to Epifania San Pedro, representing a lot in San Juan, Balagtas, Bulacan measuring 12,108 square meters. After San Pedro’s death, Pelagio Francisco, Sr. claimed ownership through an affidavit of self-adjudication, resulting in cancellation of the original certificate of title and issuance of a Transfer Certificate of Title (TCT) in his name on October 25, 1990.
Pelagio Francisco sold the property to Tanduay Lumber on December 3, 1990, which led to further subdivision and issuance of various TCTs to different parties,
...
Case Digest (G.R. No. L-15654)
Facts:
- Issuance of Original Title and Transfers
- Epifania San Pedro was issued Free Patent (FP) No. (III-12) 17306 on May 20, 1987, with Original Certificate of Title (OCT) No. P-22-C covering Lot No. 3070, Cad-333, San Juan, Balagtas, Bulacan, measuring 12,108 square meters.
- Upon her death, Pelagio Francisco, Sr. executed an Affidavit of Self-Adjudication as her sole surviving heir, resulting in cancellation of OCT No. P-22-C and issuance of Transfer Certificate of Title (TCT) No. T-7836 on October 25, 1990, in his name.
- On December 3, 1990, Pelagio Francisco sold the property to Tanduay Lumber, Inc.; TCT No. T-7836 was cancelled and TCT No. P-8582 was issued to Tanduay Lumber.
- Subdivision and Subsequent Transfers
- Tanduay Lumber subdivided Lot No. 3070 into Lot Nos. 3070-A and 3070-B under approved Plan Psd-03-0778111. TCT No. T-24663 issued to Nolasco R. Capati, Sr. for Lot 3070-A (by Deed of Exchange), and TCT No. T-24664 to Tanduay Lumber for Lot 3070-B.
- Lot 3070-A transferred from Nolasco R. Capati, Sr. to Winston T. Capati, with TCT No. T-44191 issued to Winston T. Capati. Lot 3070-A further subdivided into Lots 3070-A-1 and 3070-A-2; Lot 3070-A-1 registered to Verbo Realty by sale, Lot 3070-A-2 to Winston T. Capati.
- Lot 3070-B subdivided into Lots 3070-B-1 to 3070-B-9; certain lots sold or transferred to various parties including Spouses Clemente and Maria Lourdes Garcia, John Michael H. Artienda, Spouses Teodoro and Angelita Chan, Licerio M. Libunao, Maricris A. Melchor, Maricris C. Armado, and Winston T. Capati, with corresponding titles issued to each transferee.
- Petition for Cancellation of Title and Proceedings
- On January 31, 2011, Arturo and Teresita Mendoza, represented by counsel, petitioned the Office of the Solicitor General (OSG) to cancel Patent No. P-22-C and all derivative titles, alleging violation of the Public Land Act’s five-year alienation prohibition.
- OSG referred the petition to the Regional Executive Director (RED), DENR, Region III, who after investigation recommended filing a reversion suit based on violations of Sections 118, 121, and 122 of Commonwealth Act (C.A.) No. 141.
- The Republic of the Philippines, represented by DENR Region III, filed a Complaint for Cancellation of Title/Reversion on August 31, 2014, against Tanduay Lumber, Verbo Realty, various private respondents, and the Register of Deeds of Bulacan.
- The private respondents, except Tanduay Lumber whose whereabouts were unknown, filed answers, counterclaims, and special and affirmative defenses of laches, estoppel, and prescription. They presented evidence supporting these defenses.
- The RTC, Branch 13, Malolos, Bulacan, on September 3, 2015, granted the respondents’ special and affirmative defenses and dismissed the complaint on grounds of equitable estoppel and laches.
- The petitioner’s motion for reconsideration was denied by the RTC on March 4, 2016.
- The petitioner filed a Rule 45 Petition for Review on Certiorari before the Supreme Court on May 23, 2016.
Issues:
- Whether the petitioner’s Complaint for Cancellation of Title/Reversion is barred by equitable estoppel and laches.
- Whether the five-year prohibition on alienation under Sections 118, 121, and 122 of C.A. No. 141 applies given the enactment of Republic Act No. 11231 ("Agricultural Free Patent Reform Act").
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)