Case Summary (G.R. No. 231001)

Petition for Review on Certiorari

• The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
• The petitioner, Constantino Belizario, challenges the Decision and Resolution of the Court of Appeals (CA) which denied his Rule 65 petition for certiorari.
• The CA affirmed the Orders of the Regional Trial Court (RTC) of Balayan, Batangas, which directed the cancellation of Belizario's Transfer Certificate of Title (TCT) No. T-51621.

Background of the Case

• The Republic of the Philippines filed a complaint in 1960 for annulment of titles against Ayala y Cia and others, alleging illegal inclusion of public lands in their titles.
• The Court of First Instance (CFI) ruled in favor of the Republic, declaring certain titles null and void and reverting the lands to public dominion.
• The Supreme Court affirmed this decision in 1965, confirming that the excess areas claimed by the Ayalas were public lands.

Execution of the CFI Decision

• Despite the Supreme Court's ruling, execution of the annulment and reversion was delayed for over two decades.
• In 2006, the Supreme Court directed the RTC to proceed with the execution of the CFI Decision.
• The RTC ordered the Department of Environment and Natural Resources (DENR) to conduct a relocation survey to facilitate the execution.

Petitioner’s Acquisition of Land

• Constantino Belizario purchased a parcel of land from the Ministry of Agrarian Reform in 1987, which was later found to be a derivative title of TCT No. 722.
• The RTC ordered the cancellation of Belizario's TCT based on findings from the Technical Working Committee (TWC) that the land was part of the excess area of TCT No. 722.

RTC Orders and Petitioner’s Arguments

• Belizario filed a Motion to Exclude, arguing that his title was not derived from TCT No. 722, but the RTC denied this motion.
• The RTC found insufficient evidence to support Belizario's claims and upheld the TWC's findings.
• Belizario's subsequent motion for reconsideration was also denied.

Court of Appeals Ruling

• The CA affirmed the RTC's orders, stating that Belizario's arguments lacked merit.
• The CA ruled that a reversion suit can nullify a void title, and Belizario, as a successor of the Ayalas' excess land, was bound by the execution of the CFI Decision.

Legal Principles on Reversion and Title

• The CA emphasized that a void title does not enjoy indefeasibility under the Torrens system.
• The Court reiterated that the State can reclaim public lands even if they were sold erroneously by government officials.
• The principle that registration under the Torrens system does not confer ownership was highlighted.

Findings on the T...continue reading

Case Syllabus (G.R. No. 231001)

Introduction

• The case revolves around a Petition for Review on Certiorari, filed by Constantino Y. Belizario against the Department of Environment and Natural Resources (DENR) and the Registry of Deeds of Nasugbu, Batangas.
• The Petition challenges the Decision dated January 13, 2017, and the Resolution dated March 27, 2017, of the Court of Appeals (CA) in CA-G.R. SP No. 141450.
• The core of the dispute involves the annulment of titles and the subsequent claims to land originally belonging to the public domain.

Procedural Background

• The CA Decision denied Belizario's Rule 65 petition for certiorari and affirmed Orders from the Regional Trial Court (RTC) of Balayan, Batangas, relating to Civil Case Nos. 373 and 653.
• The Orders being contested included those from June 28, 2011, March 19, 2012, and May 20, 2015, which dealt with the cancellation of titles derived from TCT No. 722.

Factual Antecedents

• On May 12, 1960, the Republic of the Philippines initiated a complaint for annulment of titles against Ayala y Cia and others, asserting that their titles included portions of public domain land.
• The Court of First Instance (CFI) of Batangas ruled in favor of the Republic, declaring several titles, including TCT No. T-9550, null and void, and reverting the lands to public dominion.
• The Supreme Court upheld this ruling in 1965 and emphasized the continued illega...continue reading