G.R. No. 237663 - Republic vs. Heirs of Bernabe

Case Summary (G.R. No. 237663)

Factual Synopsis

The subject land formed part of a 1908 U.S. military reservation never declared alienable public domain. A cadastral decision in 1967 adjudicated an Original Certificate of Title to Francisco Garcia, later transferred to Bernabe. A Bureau of Lands survey confirmed the parcel lay within active military reservation. In 1993, Proclamation 163 transferred Clark Air Base lands (including the parcel) to the BCDA to govern the Clark Special Economic Zone.

Issues Presented

Whether the Republic is the real party in interest entitled to invoke imprescriptibility of action.
Whether the VCAFS signed by the BCDA President and CEO was valid.

Real Party in Interest Analysis

Under Rule 3, Sec. 2, the real party in interest stands to be benefited or injured by the judgment. The CA relied on Shipside, Inc. v. CA (2001), which held that lands transferred to BCDA became BCDA’s property, relegating the Republic to secondary status. The petition contends that subsequent jurisprudence—particularly Manila Int’l Airport Auth. v. CA (2006) and BCDA v. CIR (2018)—classifies BCDA as a government instrumentality with corporate powers, not as an independent GOCC, and that beneficial ownership remains with the Republic.

Beneficial Ownership Doctrine

In Manila Int’l Airport Auth., the Court held that MIAA, despite holding title, acted as trustee; beneficial ownership of airport lands remained with the Republic, as only the President could convey such properties (Admin. Code, Sec. 48). GSIS and other instrumentalities were likewise deemed trustees. RA 7227’s grant of ownership, administration, and disposition powers to BCDA did not divest the Republic of beneficial ownership, because BCDA could not dispose of lands without presidential approval and proceeds remained subject to statutory disposition schemes. Thus, the Republic retained beneficial ownership of Clark Air Base lands.

Overruling Shipside Precedent

The Supreme Court recognized that Shipside’s conclusion—treating BCDA as a proprietor of transferred lands—conflicts with the trustee doctrine reaffirmed in Manila Int’l Airport Auth. and BCDA v. CIR. It therefore overruled Shipside insofar as it denied the Republic standing in reversion actions involving military reservations transferred to BCDA. Henceforth, the Republic, as beneficial owner, is the real party in interest and can file reversion proceedings.

Verification and Certification Against Forum Shopping

CRBB challenged the VCAFS on the ground that the BCDA President lacked board