Title
Sulo ng Bayan, Inc. vs. Gregorio Araneta, Inc.
Case
G.R. No. L-31061
Decision Date
Aug 17, 1976
Sulo ng Bayan, Inc. sought land ownership, claiming fraudulent title issuance. SC dismissed, citing lack of cause of action; corporation lacked standing, not a class suit.
A

Case Digest (G.R. No. L-31061)

Facts:

  • Parties and Subject Matter
    • Plaintiff-Appellant Sulo ng Bayan, Inc. is a non-stock corporation organized under Philippine law, with its membership composed of natural persons residing in San Jose del Monte, Bulacan.
    • Defendants-Appellees are Gregorio Araneta, Inc., Paradise Farms, Inc., National Waterworks & Sewerage Authority (NWSA), Hacienda Caretas, Inc., and the Register of Deeds of Bulacan. They hold Torrens-registered titles to a tract of land in San Jose del Monte, Bulacan, measuring approximately 27,982,250 square meters.
  • Allegations in the Amended Complaint
    • The members of Sulo ng Bayan, Inc. (through themselves and their predecessors) pioneered in clearing and cultivating the subject land since the Spanish era, possessing it openly, publicly, and adversely.
    • In 1958, Gregorio Araneta, Inc. allegedly ejected the members by force and intimidation. Only in 1961 did the members learn that the land had been fraudulently included in Original Certificate of Title (OCT) No. 466 (May 11, 1916) without any original survey or notice to adverse possessors, rendering the title void.
    • All subsequent titles derived from OCT No. 466—including Transfer Certificates of Title (TCTs) Nos. 4903, 7573 (in favor of Gregorio Araneta, Inc.), 4988 (NWSA), 4986 (Hacienda Caretas, Inc.), and one in the name of Paradise Farms, Inc.—are likewise void.
  • Procedural History
    • On April 26, 1966, Sulo ng Bayan, Inc. filed an action in the Court of First Instance, Bulacan, Fifth Judicial District, Valenzuela, Bulacan, for:
      • Nullification of OCT No. 466 and all derivative TCTs;
      • Declaration of its members as absolute owners in common and issuance of a new certificate of title in the corporation’s name; and
      • Damages against Gregorio Araneta, Inc.
    • Defendants Gregorio Araneta, Inc., Paradise Farms, Inc., and Hacienda Caretas, Inc. moved to dismiss for lack of cause of action, prescription, and laches; NWSA asserted the same defenses in its answer.
    • Plaintiff moved to transfer the case to the Malolos branch of the same court. Defendants opposed, and service defects arose.
    • On January 24, 1967, the trial court dismissed the amended complaint for lack of cause of action and prescription, and denied the transfer as moot. A motion for reconsideration was denied on February 22, 1967.
    • The plaintiff appealed to the Court of Appeals, which, finding only questions of law and jurisdiction, on September 3, 1969 certified the case to the Supreme Court.

Issues:

  • Jurisdiction and Venue
    • Whether the trial court acted without authority in denying the motion to transfer the case to the Malolos branch despite authorization by the Secretary of Justice.
    • Whether the Secretary’s “authorization” divested the original branch of jurisdiction or changed the venue.
  • Real Party in Interest and Cause of Action
    • Whether a non-stock corporation may sue on behalf of its individual members to recover land owned in their personal capacities.
    • Whether the corporation had any legal or equitable interest in the subject property to constitute a cause of action.
  • Class Suit Applicability
    • Whether the amended complaint could be treated as a class suit under Section 12, Rule 3 of the Revised Rules of Court, given the alleged common interest of the members.
  • Prescription and Laches
    • Whether the action for reconveyance of fraudulently registered real property had already prescribed or was barred by laches.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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