G.R. No. 156888 - Santiago vs. Subic Bay Metropolitan Authority

The action arose from a Complaint for Recovery of Possession of Property filed on March 12, 2002, before the RTC of Olongapo City, Zambales, Branch 74, in Civil Case No. 126-0-2002.
The Complaint involved Victoria M. Rodriguez, Armando G. Mateo, and Pedro R. Santiago (the petitioner) against the Subic Bay Metropolitan Authority (SBMA) as respondent.
Included in the complaint was a prayer for both the issuance of a Writ of Preliminary Injunction (and/or Temporary Restraining Order) and the recovery of possession of the property.

Plaintiffs alleged that Victoria M. Rodriguez was the sole heir and administrator of the estate of Hermogenes Rodriguez, with supporting documentation (i.e., a Spanish title—Titulo de Propriedad de Terrenos of 1891 under a Royal Decree).
It was claimed that in the lifetime of Hermogenes Rodriguez, he owned parcels of land registered under the Spanish title, which later were leased for 50 years to Santiago and Mateo, thereby giving Santiago the right to occupy part of the land (specifically a 2.5-hectare parcel at 717 Sta. Rita Road).
Defendants, while acknowledging they were not the owner, were alleged to be asserting possessory, if not proprietary, rights over the disputed parcels by using the land for commercial and other purposes.

SBMA contended that petitioner Santiago’s wife, Liwanag Santiago, had availed of a housing privilege accorded to SBMA employees in 1998, which allowed her to lease a housing unit within the Subic Bay Freeport Zone.
The lease was subject to termination upon the cessation of her employment with SBMA. After her employment concluded on January 31, 2002, SBMA maintained that she (and her family) were required to vacate the premises as stipulated in the SBMA Housing Policy.
This position was supported by SBMA’s documents including notices to vacate and their counter statement of facts.

On March 13, 2002, a Temporary Restraining Order was issued by the RTC to prevent SBMA from ousting Santiago and his family from the housing unit pending further hearings.
During further hearings on the application for a Writ of Preliminary Injunction, instead of filing an Answer, SBMA filed a Motion to Dismiss the complaint on the ground that the complaint failed to state a valid cause of action.
On December 3, 2002, the RTC denied the application for the writ and dismissed the complaint. The RTC ruled that the right claimed by plaintiffs, based on a Spanish title, was no longer valid under PD No. 892 which mandated registration under the Torrens system by a fixed deadline (until August 16, 1976).

Plaintiffs filed a Motion for Reconsideration, which was denied in a second order dated January 7, 2003.
Petitioner Santiago later elevated the case by filing a petition for review on certiorari under Rule 45 of the Rules of Court because the issues raised were purely questions of law.

Whether or not Spanish titles are still admissible as evidence of land ownership.

Whether the dismissal was proper in light of the possibility that plaintiffs could prove their claim by evidence other than the Spanish title.

Whether the defendant’s decision to file a Motion to Dismiss (instead of an Answer) hypothetically amounted to admission of the plaintiffs’ allegations regarding ownership.