Case Summary (G.R. No. 81564)

Allegations of Grave Abuse of Discretion

The petitioners accuse Judge Francisco Velez of the Regional Trial Court, Branch 57, of grave abuse of discretion for authorizing Domingo Palomares, the private respondent, to exercise acts of ownership over a 2,574-hectare parcel of land known as Hacienda de Maricaban. The facts of the case are undisputed. On November 5, 1985, Palomares, as administrator of the heirs of Delfin Casal, initiated a suit for declaratory relief, quieting of title, and cancellation of certain titles related to the property. Previous petitions by Palomares had been denied by the Supreme Court for lack of merit. The petitioners filed their answer on December 19, 1985, and subsequent motions and complaints ensued, leading to the current legal dispute.

• Petitioners allege grave abuse of discretion by Judge Velez.
• Palomares initiated a suit for declaratory relief and quieting of title.
• Previous petitions by Palomares were denied by the Supreme Court.
• The petitioners filed their answer on December 19, 1985.

Claims and Counterclaims

In June 1986, Palomares filed an amended complaint, asserting that the original title to the land was confirmed in 1906 and that subsequent titles were invalid. The petitioners countered that the estate of Delfin Casal was not a juridical person capable of suing, and that the registers of deeds were not the real parties in interest. They also argued that the original title had been cancelled and that res judicata and prescription barred the claims of the Casal heirs. A temporary restraining order was issued against the petitioners on August 29, 1986, and subsequent orders authorized Palomares to conduct surveys and manage the property.

• Palomares claimed original title validity and invalidity of subsequent titles.
• Petitioners argued the estate lacked legal standing and that the original title was cancelled.
• Res judicata and prescription were cited as bars to the Casal heirs' claims.
• A temporary restraining order was issued against the petitioners.

Jurisdictional Issues and Appeals

The petitioners raised several questions regarding the jurisdiction of the respondent court, the validity of the orders issued, and whether the court could decide ownership before trial. The private respondent contended that the court did not prematurely adjudicate the case and that the original title had not been validly cancelled. The respondent judge asserted that the orders were meant to maintain the status quo and did not authorize unbridled acts of ownership. The petitioners filed a notice of appeal, which was denied by the respondent court as it was deemed an interlocutory order.

• Petitioners questioned the jurisdiction and validity of the court's orders.
• Private respondent claimed the court did not prematurely adjudicate the case.
• The respondent judge maintained that the orders were to maintain the status quo.
• The petitioners' notice of appeal was denied as interlocutory.

Examination of Original Certificate of Title No. 291

The Court examined whether Original Certificate of Title No. 291 was still valid. It noted that the land covered by TCT No. 192 had been designated as government property through various proclamations. The Court found that the original title had been duly cancelled and that the land had been ceded to the National Government. The private respondent was tasked with proving that portions of the property claimed were indeed outside the government reservations, which he failed to do.

• The Court assessed the validity of Original Certificate of Title No. 291.
• The land was designated as government property through proclamations.
• The original title was found to be duly cancelled.
• The private respondent failed to prove claims regarding the property.

Grave Abuse of Discretion by the Respondent Judge

The Court concluded that Judge Velez committed grave abuse of discretion by issuing orders that effectively transferred government property without notice to the registered owners. The judge's actions lacked due process, as the current holders of the land were not given an opportunity to defend their interests. The Court emphasized that the ord...continue reading

Case Syllabus (G.R. No. 81564)

Case Overview

• The case involves two consolidated petitions (G.R. No. 81564 and G.R. No. 90176) regarding a 2,574-hectare parcel of land known as Hacienda de Maricaban.
• The petitioners are the Acting Registrars of Land Titles and Deeds of Pasay City, Pasig, and Makati, while the respondents include the Regional Trial Court of Makati and the intestate estate of the late Delfin Casal.
• The main contention arises from an order by Judge Francisco Velez, allowing Domingo Palomares to exercise acts of ownership over the contested property.

Background and Procedural History

• On November 5, 1985, Domingo Palomares, acting as the administrator of the heirs of Delfin Casal, filed a suit for declaratory relief and cancellation of titles in the Regional Trial Court, Makati.
• The court had previously denied a similar petition by Palomares on February 27, 1985.
• The case was marked by a series of motions and orders, including an order from Judge Velez allowing Palomares to perform acts of ownership and management over the land.

Key Issues Raised by Petitioners

• Petitioners contend that the respondent court cannot validly adjudicate ownership or possession of the...continue reading