Case Summary (No G.R. Number Supplied)
Applicable Law
The 1987 Philippine Constitution applies to this case as it was decided after 1990.
Factual Background
Green Square Properties Corporation acquired a tract of land approximately 50,497 hectares in size from the estate of Don Mariano San Pedro y Esteban through a deed of sale. This land had been previously declared null and void under Titulo de Propriedad No. 4136 in an earlier Supreme Court ruling. After the sale was confirmed, the tax declaration for the property was transferred to Green Square.
Nature of Dispute
Green Square's tender of payment for real estate taxes was refused by the Municipal Treasurer's office in General Nakar, prompting them to file a complaint for quieting of title and mandamus. They contended that the refusal to accept payment created uncertainty regarding their rights and interests in the property.
Trial Court Proceedings
The petitioners moved to dismiss the complaint, asserting that Green Square's case was barred by res judicata due to the previous Supreme Court ruling invalidating Titulo de Propriedad No. 4136. However, the trial court denied the motion, asserting that Green Square had established legal title and had been in possession of the land for over thirty years. The court also determined that the matter of whether the property was covered by the void title was a legitimate issue for trial.
Grounds for Petition
The petitioners brought the case to the Supreme Court on three grounds, alleging that the respondent judge abused his discretion by disobeying the prior ruling, by mischaracterizing the issues in the case, and by concluding that the complaint was not barred by prior judgment.
Analysis of Issues
- Dispute Over Land Coverage: The Supreme Court found that both parties accepted the coverage of the land under Titulo de Propriedad No. 4136, thus the trial court erred in making this a matter for trial.
- Res Judicata Application: The court underscored that the issues between the current complaint and the previous ruling were the same. The earlier decision rendered Titulo de Propriedad No. 4136 null and void, affecting Green Square's claim which reli
Case Syllabus (No G.R. Number Supplied)
Case Citation
- G.R. No. 139274
- Date of Decision: October 23, 2001
- Philippine Reports Citation: 420 Phil. 177
Parties Involved
- Petitioners:
- Quezon Province, represented by its Governor, Wilfrido L. Enverga
- Liwayway R. Lareza, in her capacity as Municipal Treasurer of General Nakar, Quezon
- Respondents:
- Hon. Abelio M. Marte, Presiding Judge of Regional Trial Court, Branch 65, Infanta, Quezon
- Green Square Properties Corporation, represented by its President, Romeo G. Roxas
Background and Facts of the Case
- Green Square Properties Corporation acquired rights over a large tract of land (50,497 hectares) from the estate of Don Mariano San Pedro y Esteban via a deed of sale dated August 14, 1996.
- The land was previously covered by Tax Declaration No. 09-019-0094 in the name of Don Mariano San Pedro and was allegedly part of Titulo de Propriedad No. 4136 dated April 29, 1894.
- A ruling from the Regional Trial Court of Bulacan confirmed the sale in Intestate Estate Proceeding No. 312-B on September 17, 1996, resulting in the cancellation of the tax declaration in Don Mariano's name and issuance of a new one in Green Square's name.
- In G.R. No. 106496, the Supreme Court declared Titulo de Propriedad No. 4136 as null and void, thereby excluding all lands covered by it from the estate's inventory, preventing any act of possession or disposal by the estate's heirs.
- In July 1998, the municipal treasurer of General Nakar refused to accept