Case Summary (G.R. No. 240047)
Antecedent Facts
The legal dispute originated from the historical establishment of Mariveles, Bataan, as a Foreign Trade Zone, culminating in the enactment of R.A. No. 9728 which converted the Bataan Economic Zone into a special economic zone and freeport known as the Freeport Area of Bataan (FAB). This transition led to the creation of AFAB to manage the FAB, subsequently transferring relevant land titles, including certain parcels under the authority of FFCCI, which were allegedly erroneously registered.
Amended Complaint and FFCCI's Motion to Dismiss
AFAB filed an Amended Complaint for the Declaration of Nullity and Cancellation of Title against FFCCI concerning the Subject Properties, asserting that these lands were reserved under Proclamations 899 and 939 and thus inalienable. FFCCI responded with a Motion to Dismiss, arguing lack of cause of action, improper jurisdiction, and that the AFAB was not the real party in interest. The RTC denied the Motion, affirming AFAB’s right to pursue the case.
Court of Appeals Decision
FFCCI subsequently petitioned the Court of Appeals, which initially affirmed the RTC's ruling but later reversed itself in an Amended Decision, granting FFCCI's Motion to Dismiss. The CA determined that the Amended Complaint did not sufficiently state a cause of action as it improperly sought to annul a prior title from a lower court, putting the reversion action within the jurisdiction of the Solicitor General rather than AFAB.
Supreme Court Ruling
The Supreme Court reviewed the CA's Amended Decision, concluding that the CA did not err in determining that AFAB was not the real party in interest, as reversion claims to public domain lands must be instituted by the Solicitor General on behalf of the State. Therefore, the correct legal standing belonged to the State, affirming that the Subject Properties should remain under public dominion and could not be privately owned.
Examination of Relevant Legal Principles
Key legal principles were discussed, including the inapplicability of prescription or laches against the State concerning reversion claims. The Court clarified that lands held as public domain
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Case Background
- The case involves a petition for review on certiorari filed by the Authority of the Freeport Area of Bataan (AFAB) seeking to annul the Amended Decision of the Court of Appeals (CA) dated June 7, 2018.
- The CA had granted the Motion for Reconsideration filed by F.F. Cruz & Company, Inc. (FFCCI) and reversed its earlier decision from July 7, 2017, which affirmed the Regional Trial Court (RTC) Orders denying FFCCI's Motion to Dismiss.
- The RTC’s Orders dated December 21, 2015, and March 30, 2016, were significant in upholding AFAB's claim over certain properties.
Legislative and Historical Context
- Republic Act (R.A.) No. 5490 was enacted on June 21, 1969, establishing Mariveles, Bataan as a principal port of entry and Foreign Trade Zone.
- Presidential Proclamations No. 899 (1971) and No. 939 (1971) reserved lands for Foreign Trade Zone purposes.
- Presidential Decree No. 66 in 1972 established the Export Processing Zone Authority (EPZA), which later became the Philippine Economic Zone Authority (PEZA) under R.A. No. 7916.
- On July 27, 2009, R.A. No. 9728 converted the Bataan Economic Zone into the Freeport Area of Bataan (FAB) and created the AFAB to manage it.
Discovery of Title Issues
- AFAB discovered that several parcels of land reserved under Proclamations 899 and 939 were erroneously registered under the name of FFCCI.
- The titles in question, identified as TCT No. T-144045, T-144046, T-144047, T-144225, and T-144226, were derived from Original Certificate of Title (OCT) No. 234 issued in December 1972.
- AFAB contended that these lands were inalienable and indisposable at the time of issuance, thus claiming th