Case Summary (G.R. No. 97973)
Background of the Case
The Republic of the Philippines initiated a legal action on May 12, 1960, against Ayala y Cia and several individuals for the annulment of certain land titles, specifically alleging that these titles unlawfully encompassed public domain lands, including territorial waters. The complaint was filed in the Court of First Instance (CFI) of Batangas as Civil Case No. 373. On June 2, 1962, the CFI rendered a decision declaring Transfer Certificate of Title No. T-9550 and other similar titles void because they included lands outside of private holdings, thereby reverting those areas to public dominion. This decision was subsequently affirmed by the Supreme Court in 1965, which identified that approximately 2,000 hectares were wrongfully occupied.
Execution Proceedings
Decades later, the execution of this decision remained largely unfulfilled due to numerous legal maneuvers by the respondents. The Supreme Court intervened by mandating the Regional Trial Court (RTC) to facilitate this reversion process, coming to light again in Republic v. Delos Angeles in 1988, affirming that previous titles could only be nullified and reverted by the state. The purpose of a relocation survey was initiated for determining the rightful boundaries of these lands, leading to the establishment of a Technical Working Committee (TWC) under the DENR.
Petitioner's Acquisition of Land
On September 17, 1987, Constantino Y. Belizario purchased a 24,961-square meter land parcel situated in Calatagan, Batangas from the Ministry of Agrarian Reform, after which he received TCT No. T-51621. However, subsequent investigations revealed that his title was derived from TCT No. 722, which was linked to the lands in question originally claimed by the Ayalas.
Legal Proceedings Against Petitioner
On July 12, 2011, the RTC issued an order to cancel Belizario’s title based on the findings of the TWC, categorizing his property as a derivative title that must follow the annulments prompted by the prior rulings. Petitioner attempted to contest this decision through a Motion to Exclude, arguing that his title should not be perceived as derived from TCT No. 722. The RTC ultimately denied this motion, leading Belizario to file a motion for reconsideration, which was also denied in 2015.
Court of Appeals Ruling
The Court of Appeals (CA) reviewed Belizario's certiorari petition, which assailed the RTC's orders. On January 13, 2017, the CA ruled to deny the petition, stating that the RTC acted within its jurisdiction and confirming that the execution of Civil Case No. 373 was correctly directed. The CA further emphasized that the reversion suit was justified as Belizario’s land, as a derivative title, inherently involved itself in the reversion matters.
Issues Presented
Belizario raised several issues on appeal, primarily asserting his lack of involvement in the reversion cases, claiming he was not bound by the earlier decisions, contesting the lack of an actual ground survey prior to the cancelation of his title, and asserting his position as an innocent purchaser for value.
Supreme Court's Rationale
The Supreme Court affirmed the CA's ruling, in
...continue readingCase Syllabus (G.R. No. 97973)
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 illegality of the titles issued