Case Summary (G.R. No. 242900)
Factual Background and Nature of Dispute
In 1970, Danilo Reyes purchased a 182,941-square-meter parcel of land in Barangay Banus, Pinamalayan, Oriental Mindoro, from Regina Castillo, who held the title under Original Transfer Certificate of Title (OCT) No. P-2388, issued pursuant to Free Patent No. V-79606. Reyes subsequently planted fruit trees, including mangoes, mandarins, and guyabano, and had the title transferred to his name as TCT No. 45232. However, about 162,500 square meters of the land was later discovered to be part of the timberland, classified as inalienable and non-disposable public forest land under DENR land classification maps. The Republic, through the Office of the Solicitor General (OSG), filed a complaint for cancellation of title and reversion, alleging that the original free patent and subsequent titles were spurious, irregularly issued, and covered timberland that could not be legally conveyed or registered.
Legal Issues Raised by the Republic
The Republic asserted that:
a) The majority of the land covered by Castillo’s and Reyes' titles was timberland in Oriental Mindoro, based on DENR Land Classification Maps Nos. 1715 and 2319.
b) The timberland overlapped with a valid Agro-Forestry Farm Lease Agreement (AFFLA) No. 175 granted in 1986 to Atty. Augusto D. Marte, who was the rightful occupant.
c) Reyes and his predecessors never had possession that could affect the State’s ownership, as the land was non-alienable and thus excluded from private disposition under existing laws.
d) The titles covering timberland were null and void ab initio.
The Republic supported its claims with documentary evidence and testimony from DENR officials and geodetic engineers confirming the illegal issuance of titles and the classification of the land as timberland.
Lower Courts’ Rulings on Title Cancellation and Reversion
The Regional Trial Court (RTC) ruled in favor of the Republic, declaring the free patent and all derived titles, including Reyes's TCT No. 45232, null and void. It ordered Reyes to surrender his owner's duplicate title and vacate the premises, reverting the land to the government subject to AFFLA No. 175. The RTC also declared that the two-hectare portion regarded as alienable was invalid for failure to secure necessary certification from the Bureau of Forest Development. Reyes’s counterclaims were denied for lack of merit.
On appeal, the Court of Appeals (CA) affirmed the RTC’s cancellation and reversion decision, which was eventually upheld by the Supreme Court, thus finalizing the ownership reversion to the State.
Motion to Remove Improvements and Controversy Over Accession
After finality of the reversion judgment, Reyes filed a motion under Rule 39, Section 10(d) of the 1997 Rules of Civil Procedure, seeking permission to remove the fruit trees he planted and to appropriate the unharvested fruits during the removal period. The Republic opposed, invoking the principle of accession under Article 440 of the Civil Code, asserting that improvements planted on public timberland (state property) should belong to the State without compensation. The Republic also contended that Reyes’s motion was barred by res judicata since it was a mere incident to the already decided reversion case, over which the RTC had lost jurisdiction.
RTC and CA Decisions on Removal of Improvements
Contrary to the Republic’s opposition, the RTC granted Reyes’s motion, recognizing him as a planter in good faith who honestly believed he owned the land based on previously issued titles. The RTC acknowledged that denying Reyes the removal of his planted improvements would unjustly enrich Atty. Marte, the current lessee, by allowing him to benefit from Reyes’s labor without cost. The court also dismissed Atty. Marte’s injunction complaint against Reyes for alleged trespass and planting within the leased area. The CA subsequently denied the Republic’s petition for certiorari, upholding the RTC’s ruling and affirming Reyes’s status as a good faith planter entitled to protections under Civil Code provisions.
Issues Raised on Petition for Review on Certiorari
The Republic’s chief complaint was that the CA and RTC improperly exercised jurisdiction over Reyes’s motion to remove improvements after the reversion case had become final and executory. The Republic maintained that:
a) Reyes’s motion was barred by prior judgment (res judicata), given that his alleged counterclaims related to improvements were already decided in the reversion case;
b) The RTC no longer had jurisdiction to modify or vary a final judgment; and
c) The decision on reversion did not contemplate or authorize removal of improvements, thus the court acted without jurisdiction in granting Reyes’s motion.
Danilo Reyes’s Defense and Arguments
Reyes countered that:
a) His motion was not a new case but incident to the reversion case, designed to address an important issue overlooked by prior decisions—the fate of his improvements as a good faith planter;
b) The land was leased to Atty. Marte after the fruit trees were already grown, and failure to allow removal of improvements or appropriation of fruits would unjustly enrich the lessee;
c) Denying his right to remove improvements would violate constitutional protections against confiscation without just compensation;
d) The Republic’s service of the petition was defective; and
e) The applicable provisions of the Civil Code (Articles 445, 448, 546) protect planters or builders in good faith, entitling them to reimbursement or the right to remove improvements without damage to the principal property.
Supreme Court’s Analysis on Ownership, Good Faith, and Improvements
The Supreme Court affirmed that:
a) The land ownership had reverted to the State as timberland, and the titles were void, consistent with the 1987 Constitution’s policies on forest lands (Sections 16, Article II; Section 4, Article XII);
b) Reyes was a planter in good faith prior to the 1987 filing of the reversion case—having possessed, cultivated, and improved the land under the bona fide belief of ownership;
c) The denial of Reyes’s counterclaims on purported claims for damages did not preclude his equitable right to compensation for improvements under Civil Code provisions for planters/builders in good faith;
d) The doctrine of unjust enrichment applies, preventing the State (and the lessee) from receiving the benefit of Reyes’s labor and investment without just compensation; and
e) Although Reyes’s rights to good faith planter status ceased upon notice of the reversion case in 1987, he is entitled to reimbursement for the period of good faith possession from 1970 to 1987.
Constitutional and Policy Considerations on Environmental Protection
The Court emphasized that allowing Reyes to physically remove the mature and fruit-bearing trees planted on timberland subject to AFFLA No. 175 would risk signifi
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Case Syllabus (G.R. No. 242900)
Facts and Background
- In 1970, Danilo Reyes purchased a 182,941-square-meter land in Barangay Banus, Pinamalayan, Oriental Mindoro from Regina Castillo, the registered owner under Original Transfer Certificate of Title (OCT) No. P-2388, issued pursuant to Free Patent No. V-79606.
- Reyes improved the land by introducing fruit trees, including approximately 1,000 mango trees, over 100 Mandarin citrus, and over 100 guyabano trees, and secured the transfer of title into his name as TCT No. 45232.
- It was later determined that about 162,500 square meters of this land were part of the timberland of Oriental Mindoro, thus inalienable and non-disposable according to existing laws and DENR land classification maps.
- The forested portion fell within the 140-hectare Agro-Forestry Farm Lease Agreement (AFFLA) No. 175, issued to Atty. Augusto D. Marte by the Ministry of Natural Resources in 1986, valid until December 21, 2011.
- The Office of the Solicitor General (OSG), acting for the Republic represented by the Bureau of Forest Development (BFD), filed a complaint for cancellation of title and reversion, alleging that the source title (OCT No. P-2388) of Castillo was spurious, fictitious, and irregularly issued.
- The complaint emphasized that neither Reyes nor his predecessors were in possession of the property at issue because of the valid AFFLA and that the land could not be the subject of disposition or acquisition as it was timberland.
- Reyes presented evidence of his long-term possession and investment in the land but failed to dispute the fundamental issue that the land’s reclassification rendered the title void.
Procedural History
- The Regional Trial Court (RTC), Branch 41 of Pinamalayan, Oriental Mindoro, through Judge Edilberto Ramos, initially ruled that the titles (Free Patent No. V-79606, OCT No. P-2388, and TCT No. 45232) were null and void ab initio and declared the reversion of the land to the government subject to AFFLA No. 175.
- Reyes was ordered to surrender the owner’s duplicate copy of TCT No. 45232 and vacate the premises.
- Reyes appealed to the Court of Appeals (CA), which affirmed the RTC decision, and his motion for reconsideration was denied.
- Reyes filed a petition for review on certiorari with the Supreme Court, which was also denied, with finality, in 1997.
Motion to Remove Improvements and Subsequent Orders
- On February 4, 1998, Reyes filed a motion under Rule 39, Section 10(d) of the 1997 Rules of Civil Procedure to remove his improvements (fruit trees) from the land within one year, requesting also to be allowed to harvest the fruits during that period.
- The government opposed this motion, invoking Article 440 on accession, arguing that the timberland was property of public dominion and that there were no legitimate improvements to speak of since the land remained government property.
- The RTC granted Reyes' motion, allowing him one year to remove the improvements and appropriating the unharvested fruits to him.
- The RTC denied the complaint filed by Atty. Marte alleging encroachment and bad faith on said land.
- The OSG filed a motion for reconsideration, which the RTC denied.
- Petitioner then filed a petition for certiorari with the CA alleging grave abuse of discretion and lack of jurisdiction by the RTC in granting the motion to remove improvements; however, the CA dismissed the petition and affirmed the RTC ruling.
Issues
- Whether the RTC and CA erred in granting Reyes’ motion to remove improvements on property subjec