Case Digest (G.R. No. 198878)
Facts:
Residents of Lower Atab & Teachers Village, Sto. Tomas Proper Barangay, Baguio City, represented by Beatrice T. Pulas, Cristina A. Lappao, Michael Madiguid, Florencio Mabudyang and Fernando Dosalin v. Sta. Monica Industrial & Development Corporation, G.R. No. 198878, October 15, 2014, the Supreme Court Second Division, Del Castillo, J., wrote the decision.In May 2001 the petitioners (residents of portions of the Baguio townsite reservation) filed Civil Case No. 4946‑R in the Regional Trial Court (RTC) of Baguio City seeking quieting of title with damages against Sta. Monica Industrial & Development Corporation. They alleged they were successors or transferees‑in‑interest of Torres, who allegedly possessed and declared the subject property (described in the complaint as consisting of 177,778 square meters — the record elsewhere notes “around 8.7 hectares”) since 1918; that they declared and paid taxes on their lots; and that respondent began erecting a fence claiming ownership by virtue of Transfer Certificate of Title No. T‑63184, which petitioners asserted derived from Original Certificate of Title No. O‑281 and was void under Presidential Decree No. 1271 (PD 1271) and the decision in Republic v. Marcos. They prayed that TCT No. T‑63184 be cancelled, for damages, attorneys’ fees, costs, and injunctive relief.
Respondent answered, denied petitioners’ claim of title and argued the suit was a collateral attack on a valid Torrens title; it also filed a counterclaim. In their pre‑trial brief and memorandum petitioners admitted they had applied for the purchase of their lots through townsite sales applications with the Department of Environment and Natural Resources (DENR), evidence the trial court and higher courts later relied upon.
After trial, the Baguio RTC (Branch 6, after re‑raffle) issued a December 6, 2004 decision dismissing the complaint and the counterclaim, ruling that the action constituted a collateral attack upon a title that had become indefeasible one year after registration; the trial court noted an annotation (Entry No. 184804‑21‑159) on the dorsal of the title indicating a May 9, 1989 PD 1271 Committee resolution validating the predecessor title. Petitioners’ motion for reconsideration before the RTC was denied.
On appeal to the Court of Appeals (CA, CA‑G.R. CV No. 84561), the CA affirmed by its August 5, 2011 decision. The CA held petitioners had neither legal nor equitable title, that tax declarations and receipts are not incontrovertible proof of ownership, that the suit amounted to an impermissible collateral attack (citing Section 48 of P.D. 1529), and that under PD 1271 the Solicitor General is the proper party to institute reversion actions for lands covered by void titles; the CA also found the dorsal annotation validating the title and observed no government agency disputed that validation. The CA denied petitioners’ motion for reconsideration in an ...(Subscriber-Only)
Issues:
- Do petitioners have a cause of action to maintain an action for quieting of title against respondent?
- Was the RTC and CA correct in treating petitioners’ suit as a collateral attack on respondent’s Torrens title?
- Should the case instead be treated as an action to annul respondent’s title for fraud such that the Solicitor General is the proper party to file for reversion?
- Was the validation of TCT...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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