Case Digest (G.R. No. L-47859)
Facts:
San Mauricio Mining Company, Marsman and Company, Inc., and Pedro L. Moya v. Honorable Constante A. Ancheta, et al., G.R. Nos. L-47859 & L-57132, July 10, 1981, the Supreme Court Second Division, Barredo, J., writing for the Court.The dispute concerns a parcel of land in Jose Panganiban, Camarines Norte (roughly 200 hectares) that was the subject of a chain of conveyances, adverse-claim annotations, and litigation. The property appeared on Torrens title in favor of the National Shipyards and Steel Corporation (NASSCO) (Original Certificate of Title No. 0440) and was later conveyed by NASSCO to Philippine Smelters Corporation (SMELTERS) by a Deed of Sale dated December 29, 1975; SMELTERS thereafter obtained Transfer Certificates of Title Nos. 13060 and 13502–13521 after subdivision. On August 16, 1976 petitioners (San Mauricio, Marsman and Pedro L. Moya) caused an annotation of adverse claim to be entered on the relevant titles, asserting that earlier transactions (including a November 19, 1957 deed and subsequent assignments) vested mining claims, surface rights and improvements in San Mauricio and later in Marsman.
On February 28, 1977 SMELTERS filed Civil Case No. 2882 in the Court of First Instance of Camarines Norte seeking removal of cloud over its Torrens titles, declaration of nullity of the adverse claim and damages. San Mauricio and Marsman answered and, on May 17, 1977, filed a third‑party complaint against NASSCO and certain land registration officials asserting that NASSCO had previously sold or reconveyed surface/mining rights to them and that NASSCO lacked authority to re‑sell the same lands to SMELTERS. NASSCO’s answer invoked, inter alia, Presidential Decree No. 837 (Dec. 6, 1975), which it said vested title in NASSCO and authorized disposition. NASSCO also pleaded that its corporate existence expired January 6, 1976, and raised other defenses.
SMELTERS moved for summary judgment as to Lot 261‑C; the trial court issued a partial summary judgment (September 22, 1977) declaring SMELTERS lawful owner of Lot 261‑C and directing cancellation of the adverse claim insofar as that lot. A writ of execution pending appeal was issued November 15, 1977. Pedro Moya’s counterclaim was initially struck and was the subject of certiorari proceedings in the Court of Appeals; the counterclaim was later ordered admitted and litigated. Trial on the merits proceeded; plaintiff (SMELTERS) presented witnesses and documentary evidence, defendants mostly documentary exhibits and depositions. SMELTERS moved to admit an amended complaint to conform to evidence (including an allegation that a purported presidential indorsement was forged); the trial court admitted the amendment. After trial the Court of First Instance rendered a final judgment on August 21, 1979: it canceled the adverse claims on many TCTs, declared SMELTERS the true owner entitled to possession and surface rights, awarded SMELTERS P7,587,843.98 in damages (itemized), declared the sheriff’s certificate of final sale null and void, dismissed defendants’ counterclaim and their third‑party complaint against NASSCO, and ordered costs (the decision contains extended factual findings including a determination that the 1957 transfer conveyed the mining claims to NASSCO and that certain presidential indorsements were forged).
Appellants sought review. The appeal from the final judgment had been taken initially to the Court of Appeals but was forwarded to the Supreme Court by order dated March 12, 1980; briefs previously filed in the C...(Subscriber-Only)
Issues:
- Did the Deed of Transfer of November 19, 1957 from San Mauricio Mining Company to NASSCO convey the twenty mining claims and mineral rights (and not merely "surface rights")?
- If the 1957 deed conveyed the mining claims, did Proclamation No. 500 (Dec. 23, 1968) or Presidential Decree No. 837 (Dec. 6, 1975) divest or otherwise invalidate the vested rights of San Mauricio/Marsman?
- Was the Deed of Sale dated December 29, 1975 by NASSCO to Philippine Smelters Corporation valid and effective, despite appellants’ contentions that NASSCO had previously sold the same interests and that approvals were defective or consideration inadequate?
- Did the trial court correctly order cancellation of the adverse claims, declare SMELTERS the absolute owner and award damages as it did?
- Was the Sheriff’s Certificate of Final Sale (in favor of Marsman) null and void as the trial court held?
- Was dismissal of the third‑party complaint against NASSCO correct because NASSCO’s corporate life and the three‑year survival period under Section 77 of the Corporation Law had expired?
- Were the trial court’s partial summary judgmen...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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