Title
Pinlac vs. Court of Appeals
Case
G.R. No. 91486
Decision Date
Jan 19, 2001
WWII veterans claim 502-hectare land in Quezon City, alleging adverse possession. Partial decision nullifying titles annulled due to defective summons, lack of jurisdiction, and due process violations.
class suit
quieting of title
disputed land
A

Case Summary (G.R. No. 191712)

Factual Background

The dispute arose over an aggregate of approximately 502 hectares located in Old Balara, Sitio Veterans, Barrio Payatas and Silangan, Quezon City. The petitioners asserted that the land formed part of government forest lands and that they and their predecessors had occupied the parcels continuously, openly and adversely for more than thirty years. The petitioners filed a class action for Quieting of Title in the RTC, praying that their prescriptive rights be recognized and that titles claimed by various respondents be declared null and void. Several titled owners of subdivided parcels within the disputed area, including interests associated with Vil‑Ma Maloles Subdivision, were impleaded as respondents. Personal service could not be effected on some named defendants and the trial court authorized service by publication. Publication was effected in the periodical Metropolitan Newsweek, edited and published in Caloocan City and Malolos, Bulacan.

Trial Court Findings

The RTC found that the controversy involved three parcels (Lots 1, 2 and 3) and made detailed factual findings concerning the origin and alleged irregularities of multiple Torrens instruments. The court found that certain mother titles and subsequent TCTs lacked technical descriptions on their faces and that fraudulent resurveys had expanded actual areas, producing numerous questionable titles. The RTC also found that the petitioners and their predecessors had been in continuous, public, open and uninterrupted possession of the lots for thirty years by virtue of World War II veterans’ occupancy and tacking. The Bureau of Forest Development had certified the lots as part of unclassified public forest, but the court recited evidence that the Bureau knew of and tolerated the petitioners’ occupation and had issued ordinary residential permits to some occupants.

Partial Decision of the RTC

The RTC resolved the sole issue whether petitioners were entitled to the lands they occupied and ruled in their favor. The court concluded that several mother titles and their derivatives were null and void ab initio for lacking technical descriptions and for having been fraudulently expanded. The RTC further concluded that, despite Bureau of Forest Development certifications, the character of the lands was doubtful and that the petitioners had acquired title by extra‑ordinary prescription of thirty years since the lands were susceptible of private ownership. The court declared petitioners absolute owners in fee simple of Lots 1, 2 and 3, ordered the cancellation of specified OCTs and TCTs (except those of non‑defaulting respondents), directed the Register of Deeds of Quezon City to cancel the nullified titles and to issue titles to petitioners upon application, and made the preliminary injunction permanent insofar as the cancelled areas were concerned.

Petition for Annulment in the Court of Appeals

On May 17, 1989, the titled owners of subdivided lots within Vil‑Ma filed a petition for Annulment of Judgment with Certiorari, Prohibition and Mandamus before the Court of Appeals. They contended that the RTC lacked jurisdiction over them and their titled properties. Their principal contentions were that (1) the complaint was a collateral proceeding not proper to attack registered Torrens titles except in the original registration proceeding; (2) they were not personally served and were not properly made parties because Vil‑Ma had ceased to exist as a juridical entity in 1976; (3) publication in Metropolitan Newsweek did not constitute publication in a newspaper of general circulation in Quezon City as required by law; (4) they were denied due process; (5) their registered titles were indefeasible and not susceptible to defeat by mere adverse possession; and (6) the trial court erred by receiving ex parte evidence against defaulting respondents contrary to the rules on partial default. They invoked documentary material and the Ad Hoc Committee report tracing the history of the Piedad Estate and asserting the validity of existing titles within that estate.

Court of Appeals' Interim Relief and Judgment

The Court of Appeals granted a writ of preliminary injunction on June 23, 1989 enjoining enforcement of the RTC execution upon the posting of bond. On November 15, 1989, the Court of Appeals rendered a decision annulling the RTC Partial Decision insofar as it affected the private respondents. The CA held that the publication of summons in Metropolitan Newsweek did not satisfy the requirement of publication in a newspaper of general circulation in Quezon City under P.D. 1079, Section 1, and that the RTC order failed to specify place and duration of publication as required by the Rules of Court. The CA also emphasized that Vil‑Ma Maloles Subdivision had been dissolved on January 26, 1976, and therefore could no longer be sued; the individual titled owners, who had acquired lots, should have been impleaded and notified. Finally, the CA found that the trial court violated the rule on partial default by receiving evidence ex parte against defaulted respondents when other respondents had answered, thus precluding defenses that should have inured to the benefit of non‑answering parties.

Issues Presented to the Supreme Court

In this petition for certiorari, petitioners urged that the Court of Appeals erred by (1) ignoring and leaving undecided issues raised in respondents’ answers; (2) holding that the trial court did not acquire jurisdiction over Vil‑Ma Maloles Subdivision by publication and therefore rendering the Partial Decision invalid; and (3) concluding that private respondents had a valid cause of action despite allegedly adopting contradictory positions. Petitioners sought review of the CA ruling annulling the RTC Partial Decision.

Supreme Court's Analysis

The Supreme Court observed that the action before the Court of Appeals was one for annulment of judgment and that such action is confined to two grounds: extrinsic fraud, and lack of jurisdiction or denial of due process. The Court held that the CA was not required to retry the facts or to resolve all factual issues raised by petitioners; rather, the CA needed only to determine whether the RTC lacked jurisdiction or whether the private respondents were denied due process. The Supreme Court agreed with the CA that publication in Metropolitan Newsweek did not satisfy Rule 14, Section 14, Rules of Court, because the periodical was not a newspaper of general circulation in Quezon City and because the RTC orders did not adequately specify place and duration of publication. The Court emphasized that the modes of service prescribed by statute must be strictly followed and that failure to comply is fatal to jurisdiction. The Supreme Court further held that, even if publication had been proper, service could not confer jurisdiction over an entity that had lost juridical personality. The record showed that Vil‑Ma Maloles Subdivision had been dissolved in 1976, and the individual lot owners had acquired the lots and should have been impleaded and personally notified. The Court concluded that the RTC thereby deprived the titled owners of due process by nullifying their Torrens titles without informing them or giving them an opportunity to be heard. The Supreme Court also agreed with the CA that the RTC erred procedurally in re

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