Title
Republic vs. Mangotara
Case
G.R. No. 170375
Decision Date
Jul 7, 2010
Disputes over Iligan City land parcels trace back to 1914, involving ownership claims, expropriation, quieting of title, and reversion, with rulings on indispensable parties, forum shopping, and execution pending appeal.

Case Summary (G.R. No. 170375)

Procedural Posture and Consolidation of Petitions

The Supreme Court consolidated seven petitions arising from related proceedings concerning the same land parcels: (1) an expropriation case (G.R. No. 170375) challenging RTC-Branch 1 resolutions dismissing the Republic’s expropriation action; (2) quieting of title appeals (G.R. Nos. 178779 and 178894) from the RTC-Branch 3 decision favoring Vidal and AZIMUTH; (3) ejectment/unlawful detainer matters (G.R. No. 170505; G.R. Nos. 173355-56; 173563-64) involving execution pending appeal against NAPOCOR/TRANSCO; and (4) cancellation of titles and reversion (G.R. No. 173401) where the Republic sought cancellation of OCTs and reversion of the lands to the State.

Historical Foundation: the 1914 Cacho Land-Registration Judgment

The 1914 LRC judgment (affirmed by the Court in 1914) addressed GLRO Record Nos. 6908 and 6909, finding Doña Demetria entitled only to (a) a small parcel (Lot 1) as conjugal/home property and (b) the southern portion of the large parcel (Lot 2) occupied and cultivated by Datto Anandog. The LRC required, among other conditions, presentation of a deed from Datto Darondon renouncing rights to Lot 1 and a new survey plan delimiting the southern portion of Lot 2; final decision was reserved pending compliance. These factual-locational findings are the historic baseline for subsequent disputes about the exact metes-and-bounds and whether later titles covered more land than adjudicated.

Reconstitution Litigation: the 1997 Cacho Decision

In 1978 and later, Teofilo sought reconstitution/restoration of lost decrees and OCTs. The RTC granted re-issuance of Decree Nos. 10364 and 18969; the Court of Appeals reversed; this Court in 1997 reinstated reconstitution and reissuance, concluding that the decrees had indeed been issued and attained finality and that requiring compliance with the 1914 case conditions anew would negate res judicata and destabilize the Torrens system. The 1997 decision thus effected re-issuance of OCT Nos. 0-1200 (a.f.) and 0-1201 (a.f.) in Doña Demetria’s name, but the Court clarified that the reconstitution proceeding did not conclusively resolve all ownership or boundary controversies beyond establishing the prior issuance and loss of the decrees.

Antecedent Parallel Proceedings and Fragmentation of the Dispute

After the 1997 decision, multiple independent actions arose over the same parcels: the Republic’s expropriation action (initially by ISA) and later reversion/cancellation action; Vidal and AZIMUTH’s petition for quieting of title against Teofilo and Cabildo; LANDTRADE’s unlawful detainer action against NAPOCOR/TRANSCO (supported by title claims from Teofilo); and related appeals and motions for execution pending appeal. The Supreme Court consolidated the petitions because they share factual overlap and raise interconnected legal questions regarding ownership, possession, proper parties, res judicata, prescription, and whether execution pending appeal may be allowed.

Expropriation Case (G.R. No. 170375): Background and RTC Rulings

The expropriation complaint was originally filed in 1983 by ISA against MCFC (Civil Case No. 106) after Presidential Proclamation No. 2239 reserved lands for ISA/NSC. ISA’s corporate term lapsed and the Republic sought substitution as plaintiff. The RTC initially allowed substitution but later (in orders dated April 4, July 12, and October 24, 2005) denied the Republic’s supplemental complaint, dismissed Civil Case No. 106 for failure to implead indispensable parties and for alleged forum shopping, and refused leave to admit a supplemental complaint impleading Teofilo, Vidal, LANDTRADE and AZIMUTH.

Expropriation Case: Supreme Court Analysis and Ruling

The Supreme Court reversed the RTC-Branch 1 Resolutions dismissing the expropriation complaint and ordered reinstatement and admission of the Republic’s supplemental complaint. Key legal conclusions: (a) the Republic’s consolidated petitions filed under Rules 45 and 65 were treated as a timely Rule 45 petition raising questions of law; (b) the RTC’s November 16, 2001 order substituting the Republic for ISA (in compliance with this Court’s ISA decision) remained valid and could not be nullified as an “honest mistake”; (c) non-joinder or misjoinder, including of owners, is not a ground for outright dismissal under Rule 3, Sec. 11—the remedy is to implead or add parties; (d) in expropriation proceedings the court may join occupants or claimants (occupants need not be owners) and when title appears to be in the State it is permissible to proceed against private occupants; and (e) filing a reversion action by the Republic does not automatically constitute forum shopping because the causes of action and reliefs in expropriation and reversion differ. The RTC’s dismissal was therefore reversed and the expropriation complaint reinstated.

Quieting of Title Case (G.R. Nos. 178779 and 178894): Trial Findings and Appeals

Vidal and AZIMUTH sought quieting of title (Civil Case No. 4452), alleging Vidal as Doña Demetria’s sole heir and therefore entitled to the subject properties, with AZIMUTH as successor-in-interest for part. LANDTRADE intervened claiming title to part of the properties via Deed of Sale from Teofilo. The RTC-Branch 3 found on the merits—after Vidal presented documentary and testimonial evidence and the defendants failed to present evidence—that Vidal is the granddaughter and sole heir of Doña Demetria and that Teofilo is not a son or heir; the RTC quieted title in Vidal/AZIMUTH and awarded damages. The Court of Appeals affirmed the RTC in 2007.

Quieting of Title Case: Supreme Court Review and Rationale for Affirmance

The Supreme Court denied LANDTRADE/Teofilo/Atty. Cabildo’s petitions and affirmed the RTC and Court of Appeals. The Court explained: (a) the RTC had jurisdiction under Batas Pambansa Blg. 129 to adjudicate quieting of title because assessed values exceeded jurisdictional thresholds; (b) jurisdiction over the person existed because Teofilo and LANDTRADE appeared/answered or intervened; (c) jurisdictional competence permits the trial court to exercise its jurisdiction to resolve factual and legal issues, including filiation and heirship, as necessary to determine title; (d) although certain precedents limit declarations of heirship to special proceedings, the Court recognized well-established exceptions where disposition in the civil or quieting proceeding is practical, equitable, and the issue of heirship is sharply joined and litigated—here the issue was fully tried and was necessary to dispose of Vidal’s quieting petition; (e) the 1997 Cacho reconstitution judgment did not automatically establish Teofilo’s ownership by succession—it established reissuance of decrees but did not resolve competing heirship claims or ownership beyond that reconstitution process; (f) the RTC’s factual findings (baptismal records, family tree and other documentary evidence, testimony, and the absence of any credible contesting evidence) were supported by substantial evidence; and (g) prescription and laches arguments failed because Vidal’s quieting action was timely within the 30-year prescriptive period for real actions and the defense of prescription was not raised at trial in a manner that could be entertained for the first time on appeal. Costs were awarded against LANDTRADE/Teofilo/Cabildo.

Ejectment/Unlawful Detainer Matters (G.R. No. 170505; G.R. Nos. 173355-56; 173563-64): MTCC and Appellate Proceedings

LANDTRADE obtained a favorable MTCC judgment in unlawful detainer (Civil Case No. 11475-AF) ordering NAPOCOR/TRANSCO to vacate and to pay monthly rental; the MTCC judgment was affirmed by the RTC (Civil Case No. 6613). LANDTRADE sought execution pending appeal; the RTC initially granted execution pending appeal and generated writs and garnishments. NAPOCOR/TRANSCO sought certiorari and injunction relief before the Court of Appeals and ultimately before the Supreme Court contesting the propriety of execution pending appeal and entitlement to exemptions from supersedeas bond and deposit requirements.

Ejectment: Supersedeas Bond, Deposits, Corporate Exemptions, and Mootness

The Court addressed exhaustion of remedies and procedural posture: LANDTRADE’s petition in G.R. No. 170505 was held moot and academic because the RTC had already rendered decision (December 12, 2005) affirming the MTCC, and appeals proceeded thereafter. Concerning NAPOCOR/TRANSCO’s petitions, the Court recognized past jurisprudence and statutory history that have treated NAPOCOR as exempt from filing fees and supersedeas bonds under its charter, but noted subsequent reconsiderations of such blanket exemptions by the Court of Appeals and by Supreme Court administrative resolutions. Critically, the Court emphasized that Rule 70 operates differently depending on appellate posture: Section 19 governs execution when the MTCC judgment is pending appeal before the RTC (and sets supersedeas bond/deposit conditions), but Section 21 makes the RTC’s decision immediately executory when the RTC has already ruled and the matter is on further appeal to the Court of Appeals; thus regulatory mechanics differ depending on the stage of appeal.

Ejectment: Writ of Preliminary Injunction — Public Interest and Irreparable Harm

The Supreme Court granted the consolidated certiorari petitions of NAPOCOR and TRANSCO (G.R. Nos. 173355-56; 173563-64) and set aside the Court of Appeals’ June 30, 2006 resolution to the extent it denied injunction and allowed execution. The Court ordered the Court of Appeals to issue a writ of preliminary injunction enjoining execution of the RTC’s December 12, 2005 judgment while that appeal is pending. The Court’s reasoning emphasized equitable and public-interest considerations that justified preliminary injunctive relief despite the ordinarily immediate executory nature of RTC judgments in ejectment appeals: (a) the disputed parcels were subject to multiple parallel proceedings af

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