G.R. No. 150711 - Caltex , Inc. vs. PNOC Shipping and Transport Corp.

The disputed property is part of Lot No. 3714 of the Cadastral Survey of Cagayan, encompassing approximately 126,112 square meters, situated in the Barrio of Lapasan, Cagayan de Oro City.
The origin of the controversy stems from the issuance of Original Certificate of Title (OCT) No. O-740, issued on December 13, 1977 in the name of Patricio Salcedo and his spouse, which covers not only Lot 3715 but also Lot 3714.
Subsequent to the OCT issuance, separate Transfer Certificates of Title (TCT Nos. T-55515 and T-55516) were issued to one defendant after a transaction involving the heirs of Patricio Salcedo.

The Regional Trial Court (RTC) of Misamis Oriental, Branch 17, issued a decision on February 9, 1995, dismissing the complaint against the defendants and ordering the plaintiffs (occupants) to vacate the property.
The Court of Appeals (CA) reversed the RTC ruling by setting aside the dismissal and allowing the plaintiffs-appellants to remain in possession pending the final resolution of related administrative proceedings.
The case proceeded to the Supreme Court on petition for review of the CA decision regarding the nullity of the earlier decisions and the subsequent ruling on petitioner/respondents’ legal standing.

Evidence shows that the property, although titled through an issuance in 1977, had been declared public land in an earlier judicial decision rendered on December 19, 1940 in Expediente Catastro No. 18 by Judge Ricardo Summers.
The contested factual elements include:

The existence and significance of the so-called Consing decision allegedly authorizing the Decree of Registration in favor of Patricio Salcedo.
The conflicting records between the deed of registration and the earlier declaration of the land as public.

Parties agreed in stipulations to the existence of several related cases, including Civil Cases No. 6646, 6759, and 89-243, which probed issues on the validity of the title, the tax paid, and the consequent conversion of the land status.

Plaintiffs-appellants (occupants) have been residing on and paying taxes for a portion of Lot 3714, asserting rights based on miscellaneous sales patent applications dating back as early as 1965.
Respondents, although filing the complaint for reconveyance with damages, are merely applicants for sales patents and do not claim ownership of the land.
Dispute arises because while the property is under contested title issuances, its character as public land means it should ultimately revert to the State unless granted otherwise by proper government authority.

Whether respondents, being only applicants for sales patents and not the actual owners of the land, have the proper legal standing to file an action for reconveyance with damages.
Whether equity jurisdiction can be invoked to allow parties without a direct ownership interest to continue the suit, despite the land being part of the public domain.

Whether the issuance of the OCT and subsequent TCTs are valid in light of the earlier declaration of the land as public.
The significance of the alleged Consing decision and its absence in the evidentiary record impacting the registration of the property.

Whether equitable considerations justify allowing respondents to stay in possession of the disputed land even if they are not the real parties in interest.
The implications of allowing a suit by parties who do not possess a clear enforceable right in light of established legal doctrines.

Whether the regalian doctrine and provisions of the Public Land Act, particularly Section 101, preclude private parties from acquiring title over public lands without a grant from the government.
How previous cases (e.g., Sumail v. CFI, Nebrada v. Heirs of Alivio, Lucas v. Durian, and Gabila v. Bariga) inform the issue of standing and the proper party to file a reconveyance action.