Case Summary (G.R. No. 221641)
Background of the Dispute
Dream Village Neighborhood Association, Inc. (Dream Village) claims to represent over 2,000 families that have inhabited a 78,466-square meter property in Western Bicutan, Taguig City since 1985. The land in question was originally part of the Hacienda de Maricaban and has undergone several transfers of title due to historic developments involving both the United States and Philippine governments.
Historical Overview of Property Title
Originally owned by Dolores Casal y Ochoa, the Hacienda de Maricaban, covering 2,544 hectares, was acquired by the U.S. government for military purposes, later transforming into Fort William McKinley. The subsequent titling and transfer of ownership led to the current title held by the BCDA, mandated to oversee the conversion of military reservations into civilian uses. Proclamations have designated certain lots as alienable and disposable under the law, notably Proclamation Nos. 2476 and 172, yet Dream Village contends their property is included within these proclamations.
Legal Proceedings Initiated by Dream Village
Following tensions due to perceived encroachments by the BCDA, Dream Village filed complaints with the Commission on the Settlement of Land Problems (COSLAP), seeking recognition of their long-term occupancy and application for sales patent on their respective lots. Their key argument asserts the land is outside of BCDA's domain, thus should be treated under provisions for public land disposition.
COSLAP Resolution and Jurisdiction Challenge
In its April 2004 resolution, COSLAP determined that Dream Village’s occupied lot falls outside the BCDA’s claim, leading to instructions for the Land Management Bureau to process their patent applications. However, the BCDA contested COSLAP's jurisdiction over the case, claiming that the grounds for jurisdiction did not apply as Dream Village is a holder of a title to land of public dominion and not covered under E.O. No. 561.
Court of Appeals Ruling
Upon review, the Court of Appeals ruled that COSLAP had no jurisdiction to hear the case. It emphasized that the dispute’s nature—concerning private land registered under a Torrens title—was not within COSLAP's defined scope of authority, which is limited to issues involving public lands or lands governed by specific licenses. The ruling highlighted that jurisdictional questions about the lot's classification and ownership were outside COSLAP's adjudicative powers.
Supreme Court Proceedings and Findings
Dream Village sought a petition for review to the Supreme Court, raising questions about the compatibility of the appellate court’s ruling with existing laws and decisions. However, the Supreme Court upheld the CA's decision, affirming that BCDA retains indefeasible title to F
...continue readingCase Syllabus (G.R. No. 221641)
Background of the Case
- The case involves a petition for review under Rule 45 of the Rules of Court by the Dream Village Neighborhood Association, Inc., represented by its incumbent president, Greg Seriego, against the Bases Conversion Development Authority (BCDA).
- The Court of Appeals (CA) had previously nullified and set aside a Resolution by the Commission on the Settlement of Land Problems (COSLAP) that favored the petitioners, citing lack of jurisdiction.
- The COSLAP resolution declared a property of 78,466 square meters, occupied by members of Dream Village since 1985, as outside BCDA property and allowed the occupants to apply for sales patent under relevant laws.
Antecedent Facts
- The Dream Village Neighborhood Association claims representation for over 2,000 families occupying the disputed property in Western Bicutan, Taguig City since 1985.
- The property was previously part of the Hacienda de Maricaban, owned by Dolores Casal y Ochoa and registered under a Torrens title.
- The history of the property includes several transfers, including its purchase by the US government and subsequent cession to the Republic of the Philippines in 1956.
- Various proclamations throughout the years declared portions of Fort Bonifacio, including areas in Western Bicutan, as alienable and disposable, with specific lots opened for disposition.
COSLAP Proceedings
- Dream Village filed a complaint with COSLAP in 1999, asserting its right to the property and seeking assistance in verifying its claims.
- The BCDA contested COSLAP's jurisdiction, arguing that it was merely a coordinating body and that the land in qu