G.R. No. 224076 - Republic vs. Datuin

Case Summary (G.R. No. 224076)

Petitioner’s Claims and Relief Sought

The Republic filed a complaint seeking cancellation and reversion of Original Certificates of Title (OCTs) P‑921 to P‑926 and Transfer Certificates of Title (TCTs) TP‑1937, TP‑1938, TP‑1939, TP‑1950, TP‑1951, and TP‑1952. The petition alleged the lots are inalienable (as governed by a prior final judgment in Republic v. Ayalay Cia/Hacienda Calatagan) and that fraud and irregularities attended the issuance and transfer of titles; it prayed for cancellation of the titles and reversion of the lots to the State.

Respondents’ General Position and Defenses

Respondents (notably Datuin, Dayot, Baguio Pines and Systemic) denied petitioner’s allegations. Baguio Pines and Systemic pleaded that the lots had been classified as alienable and disposable as early as May 14, 1969, that free patents/OCTs and subsequent TCTs were validly issued, and that they acquired the parcels for value with no fraud involved. They relied on documentary history tracing prior applications, certifications, and administrative directives predating the 1987 Fishpond Lease Agreement (FLA) and on a 2013 DENR Certificate of Verification indicating agricultural (alienable) status as of June 29, 1987.

Material Factual Background

July 27, 1987: FLA No. 4718 issued in favor of Prudencia V. Conlu covering a 298,688‑sq.m. public land (Lot 360, Psd‑40891).
August 19, 1987: DENR Special Work Order (SWO) 04‑001510‑D subdivided the same land into six lots, leading to issuance of OCTs P‑921 to P‑926 to six individuals (including Susan Datuin).
March 12, 1992: Register of Deeds of Nasugbu issued TCTs transferring the six lots into only two names (Susan Datuin and Evelyn Dayot).
August 1996: Datuin sold the six parcels to six corporations; corresponding TCTs were thereafter issued.
September 2003 and September 2006: DENR verifications concluded the SWO plan overlapped Lot 360 covered by FLA No. 4718 and that SWO 04‑001510‑D was not on file, implying inconsistency with Conlu’s FLA.
Prior final jurisprudence: Republic v. Ayalay Cia had declared Lot 360 (Psd‑40891) inalienable, not capable of registration. Petitioner alleges these events represent fraudulent dispossession of Conlu and invalid titles.

Procedural History through the Trial Court

The complaint (May 2010) was raffled to RTC Branch 11, Balayan, Batangas (Civil Case No. 4929). Respondents Baguio Pines and Systemic served a Request for Admission (March 5, 2012) asserting facts and the genuineness of documents; the Republic failed to respond within the Rule 26 period. Baguio Pines and Systemic moved for summary judgment (Feb. 26, 2013) relying on Section 2, Rule 26 (implied admissions). The trial court initially denied the motion for summary judgment (Order dated June 6, 2013), finding genuine issues of fact and ruling the DENR Certificate alone insufficient. After respondents’ motion for reconsideration, the trial court granted reconsideration, granted the motion for summary judgment, and rendered summary judgment in favor of respondents in a single Order dated September 3, 2013; the Republic’s motion for reconsideration of that Order was denied on December 18, 2013.

Court of Appeals Proceedings

The Republic filed a petition for certiorari with the Court of Appeals (CA) alleging grave abuse of discretion and denial of due process by the trial court’s simultaneous grant of reconsideration and rendering of summary judgment. The CA dismissed the petition for certiorari (Resolution Sept. 24, 2015), holding that summary judgment is corrected by appeal or direct review (Rule 41/Rule 45), not by a Rule 65 petition for certiorari; the CA denied reconsideration (April 11, 2016). The Republic then sought review by the Supreme Court.

Issues Framed for Supreme Court Review

I. Whether the Court of Appeals correctly dismissed the petition for certiorari as an improper remedy against the trial court’s summary judgment.
II. Whether the trial court correctly deemed the Republic to have admitted matters in respondents’ request for admission and, on that basis, properly rendered summary judgment against the Republic.

Governing Rules and Standards Applied

Rule 26 (Requests for Admission): permits written requests for admission of facts/genuineness of documents; Section 2 provides that matters are deemed admitted if not answered within the designated period, but Rule 26 is intended to expedite proceedings and not to relitigate matters already joined in the pleadings.
Rule 35 (Summary Judgment): summary judgment is proper only when (a) there is no genuine issue as to any material fact (except damages), and (b) the moving party is entitled to judgment as a matter of law. A genuine issue requires presentation of evidence at trial.
Rules of Appeal and Special Remedies: Rule 41 (ordinary appeal), Rule 65 (certiorari) — certiorari lies where a tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion and where no plain, speedy, and adequate remedy exists in the ordinary course of law.
Precedents cited by the Court: Concrete Aggregates Corp. v. CA; Po v. CA; Duque v. Spouses Yu; Paz v. CA; DepED v. Cuanan; Spouses Leynes; Narciso v. Garcia (all as selective authority in the record excerpt).

Supreme Court’s Analysis on Rule 26 and Requests for Admission

The Court held that respondents’ Request for Admission merely reproduced and sought admissions of material facts already pleaded and controverted in the parties’ pleadings. Rule 26 is not intended to compel a party to admit or deny matters already joined in prior pleadings; requests that are a mere reiteration of the pleadings fall outside the proper scope of Rule 26 and are improper as a discovery device. The Court relied on precedent (Concrete Aggregates; Po; Briboneria; Uy Chao; Duque) holding that a party need not reply to such redundant requests and that the requesting party cannot then invoke implied admissions under Section 2, Rule 26 as a basis for summary judgment when the matters were already contested in the pleadings.

Supreme Court’s Analysis on Summary Judgment and Due Process

The Court reiterated the twin requirements for summary judgment under Rule 35 and found that genuine issues of fact plainly existed — specifically, the competing assertions on whether the lots were inalienable (per Republic) or had been validly classified and disposed of as alienable and disposable since May 14, 1969 (per respondents). Where facts are disputed, summary judgment cannot replace full trial; the trial court gravely abused its discretion by treating the alleged implied admissions (from an improper Request for Admission) as extinguishing contentious factual issues. The Court also found procedural unfairness in the trial court’s single Order of September 3, 2013 that (a) granted res

Case Syllabus (G.R. No. 224076)

The Case — nature and reliefs sought

Petition to the Supreme Court by the Republic of the Philippines assails two Court of Appeals resolutions in CA-G.R. SP No. 134394: (1) Resolution dated September 24, 2015 dismissing the petition for certiorari as an improper remedy; and (2) Resolution dated April 11, 2016 denying the Republic’s motion for reconsideration.
The underlying trial action was a Complaint for cancellation and reversion filed by the Republic through the Regional Executive Director of DENR Region IV-A and the Office of the Solicitor General (filed May 13, 2010, complaint dated May 4, 2010).
The Republic prayed for cancellation of Original Certificates of Title (OCTs) P-921 to P-926, Transfer Certificates of Title (TCTs) TP 1937, TP 1938, TP 1939, TP 1950, TP 1951, and TP 1952, and reversion of the lots to the government on the ground that the lots are inalienable based on a final judgment in Republic of the Philippines v. Ayalay y Cia and/or Hacienda Calatagan, et al.
The petition before the Supreme Court invoked the Court’s discretionary appellate jurisdiction to review and reverse the Court of Appeals’ dispositions.

Antecedent factual background — titles, lease and alleged fraud

On July 27, 1987, Secretary of Agriculture Carlos G. Dominguez issued Fishpond Lease Agreement (FLA) No. 4718 to Prudencia V. Conlu, authorizing a 25-year lease over a 298,688 square meter public land in Barrio Calumbayan, Municipality of Calatagan, Batangas.
On August 19, 1987, the land was subdivided into six lots under DENR Special Work Order (SWO) 04-001510-D in favor of six individuals excluding Conlu: Lucia Dizon, Amorando Dizon, Susan Datuin, Consolacion Dizon, Ruben Dizon and Consolacion Degollacion.
Acting District Land Officer Constante Q. Asuncion and Register of Deeds Alexander Bonuan issued OCTs P-921 to P-926 to the six individuals (OCTP-921 Lucia Dizon; OCTP-922 Amorando Dizon; OCTP-923 Susan Datuin; OCTP-924 Consolacion Dizon; OCTP-925 Ruben Dizon; OCTP-926 Consolacion Degollacion).
On March 12, 1992, for reasons not explained in the record, the Register of Deeds of Nasugbu issued Transfer Certificates of Title for the six lots in the names of only Susan Datuin and Evelyn Dayot: TCTs TP 834–TP 838 in the name of Susan Datuin and TCT TP 833 in the name of Evelyn Dayot.
In August 1996, Datuin, acting alone, sold the six lots to six corporations, which were subsequently issued corresponding TCTs: TP1937 Skylon Realty Corporation, TP1938 Systemic Realty Incorporated, TP1939 Parkland Realty & Development Corporation, TP1950 Baguio Pines Tower Corporation, TP1951 Goldland Realty Corporation, TP1952 Good Harvest Realty Corporation.
On September 18, 2003, DENR verification determined the land covered by SWO 04-001510-D was not reflected in the projection map and that the area overlapped with Lot 360, Psd-40891, which was subject of FLA No. 4718. Nathaniel Abad, Chief of DENR-Projection Section, memorialized that the technical description transcribed in the title covering SWO 04-001510-D was exactly identical to Lot 0360, Psd-40891 and the total areas were essentially identical, and that plotted plans overlapped.
On September 25, 2003, DENR certified to Conlu that SWO 04-001510-D was not on its official file. A subsequent DENR verification on September 12, 2006 yielded the same results.
The Republic alleged these transfers caused Conlu’s dispossession of the property she obtained by virtue of FLA No. 4718.
The Supreme Court had earlier declared in Republic v. Ayalay y Cia (cited as 121 Phil. 1052-1057 (1965)) that Lot 360 of Psd 40891 (the land covered by FLA No. 4718) was inalienable and incapable of private appropriation; the Court affirmed the CFI decision declaring Lot 360 as part of navigable waters, or parts of the sea, beach and foreshores of the beach, thus not capable of registration.

Trial court filing and parties’ initial pleadings

The Republic’s Complaint for cancellation and reversion was docketed before the Regional Trial Court (RTC), Branch 11, Balayan, Batangas as Civil Case No. 4929; notices and summonses were sent to respondents.
Only some respondents filed answers: Susan Datuin, Evelyn Dayot, Baguio Pines Tower Corporation and Systemic Realty, Inc. filed answers; other respondents either did not answer or are not indicated as having answered in the record excerpts.
Datuin and Dayot denied the Republic’s allegations and claimed OCTs and derivative TCTs were legally issued to them.

Respondents Baguio Pines and Systemic — factual and legal defenses

Baguio Pines Tower Corporation and Systemic Realty, Inc. asserted in their Answer (dated March 30, 2011) that the lots were classified as alienable and disposable as of May 14, 1969 under Commonwealth Act No. 141 (Public Land Act) — a status preceding FLA No. 4718 (1987) — and so could not have been the subject of the 1987 FLA.
They traced title history through predecessor-in-interest Consolacion D. Degollacion: Degollacion filed Agricultural Sales Application No. (III-1) 502 on January 25, 1968 for a 29.8688 hectare parcel in Barrio Calumbayan; on May 14, 1969 Bureau of Forestry certified the area was no longer needed for forest purposes and released it as alienable and disposable.
The Chief of the Land Management Division of the Bureau of Lands directed conversion of Sales Application (III-1) 502 to a Sales (Fishpond) Application; a December 5, 1972 memorandum by the Secretary of Agriculture and Natural Resources directed processing of pending sales (fishpond) applications filed prior to the effectivity of Presidential Decree No. 43.
Baguio Pines and Systemic asserted the OCTs P-921 to P-926 were issued in 1987 and that they subsequently purchased the six lots from Datuin in 1996 for value, were issued TCTs, and had been in possession; they also averred they relied on the integrity of the titles and paid realty taxes accepted by the Republic since August 1996.
Baguio Pines and Systemic served a Request for Admission on the Republic on March 5, 2012 seeking admissions of facts and genuineness/authenticity of attached documents. The Republic failed to respond to that Request for Admission.

Respondents’ Motion for Summary Judgment and petitioner’s opposition

Relying on petitioner’s failure to respond to the Request for Admission, Baguio Pines and Systemic filed a Motion for Summary Judgment dated February 26, 2013, asserting under Section 2, Rule 26 the matters and documents subject of the Request were deemed admitted.
Respondents also contended petitioner should be deemed to have admitted a DENR Certificate of Verification dated February 20, 2013 (OIC Chief Annalisa J. Junsay) declaring the lots verified to be agricultural (alienable and disposable) as of June 29, 1987.
Datuin and Dayot adopted the motion for summary judgment; the Republic opposed the motion and filed Opposition and Supplemental Comment asserting genuine issues of fact existed and challenging the validity of the February 20, 2013 DENR Certificate of Verification, requiring presentation of evidence in trial proper.
Respondents replied, reiterating their motion for summary judgment arguments.

Trial court rulings — denial, reversal, and summary judgment

By Order dated June 6, 2013, the trial court denied respondents’ motion for sum