G.R. No. 215280 - Eizmendi, Jr. vs. Ferdez

Petitioner Vines Realty Corporation (VRC) contests the Court of Appeals (CA) Decision dated July 3, 2015, and Resolution dated May 12, 2016, which ordered the Office of the Solicitor General (OSG) to review and reinvestigate the possible reversion of a property.
Respondent is Rodel Ret, representing informal settlers claiming tenancy over the property.

The subject property is part of 144.62 hectares located in Jose Panganiban, Camarines Norte.
San Mauricio Mining Company (SMMC) originally held twenty mineral claims on this land.
On November 19, 1957, SMMC sold surface rights to National Shipyards and Steel Corporation (NASSCO), a government corporation.
By Proclamation No. 500 (1968), President Marcos reserved 170.2890 hectares of land, including the subject property, for NASSCO’s industrial facilities.
On December 6, 1975, Presidential Decree No. 837 transferred ownership of the 170.2890 hectares to NASSCO, authorizing disposition of the property.
Shortly after, on December 29, 1975, NASSCO sold the land to Philippine Smelters Corporation (PSC), a private corporation.
Titles were registered accordingly, with PSC holding Transfer Certificate of Title (TCT) No. 13060 and subsequent subdivided TCTs.

SMMC sought to assert retention of mining rights and annotated an adverse claim on the titles.
PSC filed an action for quieting of title, which was granted, declaring PSC as true and absolute owner, and removing the adverse claim.
The Supreme Court affirmed this ruling in the notable San Mauricio case (1981), which became final and executory.

PSC closed operations in 1986; its creditors, including VRC through Conrad Leviste, pursued PSC assets.
VRC obtained judicial money judgments and acquired portions of the property totaling 93 hectares through public auction and mortgage foreclosure.
VRC secured writs of possession and demolition against informal settlers, which were affirmed by the CA.
Informal settlers challenged their eviction by claiming tenancy and filed a case with the Department of Agrarian Reform Adjudication Board (DARAB), which dismissed the complaint for lack of merit and res judicata.
Enforcement of writs was suspended multiple times due to local government intervention and occupants’ resistance, prompting contempt charges upheld by courts against the informal settlers.

In 1999, informal settlers, led by respondent Ret, filed a letter complaint to Governor Pimentel alleging fraud in issuance of OCT No. 0-440, on which petitioner’s title is based.
The complaint alleged longstanding possession, improvements, and misclassification of land including foreshore areas beyond the original survey plan.
The complaint was endorsed through various government agencies and eventually led to an investigation by DENR officers, specifically Fortunata Z. Hemady.
Hemady’s November 6, 2000 Report recommended reversion proceedings citing irregularities in title issuance including:

TCT No. 13060 covered more land than authorized and lacked Presidential approval for sale;
Several lots were foreshore lands improperly titled for private ownership contrary to the Public Land Act;
Property had been used as collateral for private interest while PSC ceased operations long ago.

DENR Regional Executive Director Oscar Hamada reversed the recommendation in 2001 on grounds of res judicata based on San Mauricio.

Informal settlers escalated the matter to the Office of the President (OP) through a letter-complaint in 2004.
DENR, upon OP referral, sought comments from petitioner VRC, who asserted good faith acquisition.
On May 6, 2016, DENR issued a status quo ante order giving residents ingress/egress rights.
DENR Secretary Jose Atienza dismissed the complaint for lack of merit in 2008 and lifted status quo ante, reaffirming San Mauricio’s res judicata effect and legality of the titles.
The OP dismissed the informal settlers’ appeal for lack of cause of action in 2011 and denied reconsideration in 2013, remanding the case for proper disposition.

DENR’s Hemady report found irregularities warranting reversion;
Reversion is separate from prior ownership actions, thus res judicata does not apply;
OP wrongfully refused to direct OSG to pursue reversion investigations.

The CA granted the petition on July 3, 2015, reversing the OP decisions and ordering OSG to review and reinvestigate for possible reversion proceedings.
The CA emphasized discrepancies regarding land area, boundaries, and classification of foreshore lands vulnerable to improper titling.
The CA noted that application of res judicata was premature because San Mauricio did not cover reversion issues.
The motion for reconsideration filed by petitioner was denied by the CA in 2016.

Petitioner brought the case to the Supreme Court, challenging the CA’s reliance on Hemady’s report despite its reversal by DENR’s Regional Director.
Petitioner emphasized the necessity of DENR or LMB recommendation before OSG can file reversion, as affirmed by prior decisions and OP rulings.
Respondent argued the DENR reversal memorandum was not previously considered and that the CA’s factual findings remained valid.

Whether the OSG may initiate reversion proceedings without a recommendation from the Land Management Bureau (LMB) or DENR.
Whether the Court may compel the Office of the Solicitor General to investigate and file a reversion case despite the absence of a DENR or LMB recommendation.
Whether the doctrine of res judicata bars reversion proceedings given the finality of the San Mauricio decision affirming PSC’s ownership.
Whether the Court of Appeals erred in ordering the OSG to reinvestigate for possible reversion proceedings.
Whether the President’s power of control over executive departments and agencies may be judicially reviewed or constrained in this context.