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

Case Summary (G.R. No. 224076)

Key Dates and Applicable Law

Fishpond Lease Agreement (FLA) No. 4718 was issued on July 27, 1987.
Original Certificates of Title (OCTs) Nos. 921 to 926 were issued in 1987 to six individuals.
Transfer Certificates of Title (TCTs) were issued in 1992 in favor of Susan Datuin and Evelyn Dayot.
Subsequent sales of lots to corporations took place in August 1996.
The applicable legal framework is the 1987 Philippine Constitution, the Public Land Act (Commonwealth Act No. 141), the Property Registration Decree, and the 1997 Rules of Civil Procedure (particularly Rules 26, 35, 41, and 65).

Background and Basis of the Petition

The Republic filed a Complaint for cancellation and reversion of various titles related to six lots, alleging that these lands are inalienable public lands based on a previous Supreme Court ruling (Republic v. Ayalay Cia). The complaint contends that fraud and irregularities accompanied the transfer and issuance of titles, as the land was originally under FLA No. 4718, a lease agreement for fishpond operation over public land. Foreign certificates of title and transfers to private individuals and corporations were made without proper authority, dispossessing Prudencia V. Conlu, the lawful lessee under the FLA.

Respondents’ Defense and Counterclaims

Respondents denied the allegations, asserting that the lots had been classified as alienable and disposable since May 14, 1969, pursuant to Commonwealth Act No. 141. They traced the land's status through a series of administrative actions and certifications, arguing that the issuance of OCTs and TCTs was proper and free of fraud, and that they acquired the properties in good faith for value. Respondents also filed a motion for summary judgment, relying on petitioner’s failure to respond to their Request for Admission of facts and the authenticity of supporting documents.

Trial Court's Findings and Actions

The trial court initially denied respondents’ motion for summary judgment on the grounds that conflicting factual issues existed, which required a full-blown trial. Upon reconsideration, however, the trial court granted the motion for summary judgment and rendered judgment in favor of the respondents in a single order that also reversed its earlier denial. The court held that because the petitioner failed to respond to the Request for Admission, the facts therein were deemed admitted, including the genuineness and due execution of documents. The petitioner’s subsequent motion for reconsideration was denied.

Court of Appeals’ Rulings

The Republic petitioned the Court of Appeals for certiorari under Rule 65, alleging grave abuse of discretion and violation of due process by the trial court for deciding reconsideration and summary judgment in a single order without affording the petitioner proper opportunity for recourse. The Court of Appeals dismissed the petition, ruling that certiorari under Rule 65 was an improper remedy and that the petitioner should have taken an appeal under Rule 41 or a petition for review on certiorari under Rule 45 directly to the Supreme Court. The Court of Appeals affirmed the dismissal on motion for reconsideration.

Issues for Resolution

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 properly deemed the Republic to have admitted the matters raised in respondents’ Request for Admission, justifying summary judgment.

Legal Analysis on the Proper Remedy and Jurisdiction

The Supreme Court held that ordinarily, summary judgment decisions of the Regional Trial Court are assailed through an ordinary appeal under Rule 41. However, exceptions exist where grave abuse of discretion and violation of due process occur, in which cases a petition for certiorari under Rule 65 may be appropriate, as the remedy of ordinary appeal is not “plain, speedy, and adequate.” Past jurisprudence supports certiorari where due process rights are violated to the extent that the trial court is effectively ousted of jurisdiction.

Analysis of Request for Admission under Rule 26

Rule 26 aims to expedite trial by obtaining admissions on undisputed and material facts or documents. Here, the respondents’ Request for Admission essentially reiterated facts already pleaded and contested in petitioner’s verified complaint. The Court emphasized that a Request for Admission should clarify and narrow disputed issues, not serve as a redundancy of pleadings or an attempt to impose admissions on matters already joined and contested. Therefore, failure to respond cannot reasonably lead to implied admissions in this context.

Analysis of Summary Judgment under Rule 35

Summary judgment is appropriate only when there are no genuine issues of material fact and the movant is entitled to judgment as a matter of law. The case involves genuine disputes on whether the land was alienable or inalienable, and whether the issuance of titles was affected by fraud and irregularities. Such factual controversies require trial and could not be resolved summarily.

Due Process Violation by the Trial Court

The Supreme Court found grave abuse of discretion in the trial court’s single order granting reconsideration of its denial of summary judgment and simultaneously rendering summary judgment. This deprived t

Case Syllabus (G.R. No. 224076)

Background and Nature of the Case

The Republic of the Philippines (petitioner), represented by DENR Regional Executive Director for Region IV-A, Calabarzon, and the Office of the Solicitor General, filed a Complaint for cancellation and reversion of several land titles against the respondents (individuals and corporations) and the Register of Deeds of Nasugbu, Batangas.
The complaint sought cancellation of Original Certificates of Title (OCTs) Nos. 921 to 926 and Transfer Certificates of Title (TCTs) related thereto, with reversion of the land titles back to the government.
Grounds for cancellation included that the lots in question were inalienable government lands, and that fraud and irregularities had attended the issuance of said titles to respondents.
The complaint referenced a prior Supreme Court decision in Republic of the Philippines v. Ayalay y Cia declaring Lot 360, Psd 40891 as inalienable and incapable of private appropriation.
The case was docketed as Civil Case No. 4929 in the Regional Trial Court (RTC), Branch 11, Balayan, Batangas.

Factual Antecedents and Land History

On July 27, 1987, Fishpond Lease Agreement (FLA) No. 4718 was issued to Prudencia V. Conlu authorizing operation of 298,688 square meters of public land in Barrio Calumbayan, Calatagan, Batangas.
Subsequently, on August 19, 1987, the area was subdivided into six lots purporting to favor six individuals excluding Conlu, under DENR Special Work Order 04-001510-D, leading to the issuance of OCTs P-921 to P-926 in their names.
On March 12, 1992, the Register of Deeds of Nasugbu issued transfer certificates consolidating these lots under the names of only Susan Datuin and Evelyn Dayot.
In August 1996, Datuin sold all six lots to six realty corporations who were subsequently issued TCTs.
DENR later verified (in 2003 and repeated in 2006) that the area covered by these titles overlapped with the land covered by FLA No. 4718, which was declared in a final judgment as inalienable government land.
These alleged fraudulent transfers resulted in Prudencia V. Conlu’s dispossession of the land granted under her FLA.

Respondents’ Claims and Answer

Respondents Datuin, Dayot, Baguio Pines Tower Corporation, and Systematic Realty, Inc. filed answers denying fraud and asserting valid issuance of their titles.
Baguio Pines and Systemic maintained that the lots were alienable and disposable as early as May 14, 1969, predating the FLA issuance.
They traced the land’s legal history, including an agricultural sales application in 1968 by Consolacion D. Degollacion (a predecessor-in-interest), certification by the Bureau of Forestry releasing the land as alienable, and a memorandum from the Secretary of Agriculture and Natural Resources to continue processing fishpond applications prior to PD No. 43.
They asserted valid acquisition for value and possession starting in 1996, with no fraud in title issuance.

Procedural History in the Trial Court

Respondents filed a Request for Admission on March 5, 2012, including admissions of factual matters and authenticity of documents, to which the petitioner did not respond.
Baguio Pines and Systemic then filed a Motion for Summary Judgment on February 26, 2013, relying on the deemed admissions under Section 2, Rule 26 of the Rules of Court.
Datuin and Dayot adopted the motion; petitioner opposed citing genuine issues of fact requiring trial.
The trial court initially denied the motion for summary judgment by Order dated June 6, 2013, noting conflicting claims about fraud, land classification, and title validity necessitating evidence presentation.
Respondents moved for reconsideration; petitioner opposed, reiterating issues and disputing the validity of the February 20, 2013 DENR Certificate of Verification.
The trial court then issued a single Order dated September 3, 2013 which g