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)

Applicable Law

1987 Constitution (Art. XII, Sec. 2): Public domain lands owned by State.
Rules of Court: Rule 45 (certiorari/appeal), Rule 65 (special certiorari), Rule 3 § 11 (non-joinder), Rule 67 (expropriation), Rule 63 (declaratory relief/quieting of title), Rule 70 §§ 19–21 (ejectment appeals), Rule 58 (preliminary injunction).
Public Land Act (Sec. 101): Reversion suits by Solicitor General/State.

Expropriation Case (G.R. No. 170375)

The Republic, as successor to ISA, sought review of RTC-Branch 1 orders dismissing its 1983 expropriation complaint (Civil Case 106) for lack of indispensable parties and alleged forum shopping. The Supreme Court held:

  • RTC erred in dismissing the complaint. MCFC, as occupant, was a proper defendant; non-joinder/misjoinder does not warrant dismissal (Rule 3 § 11).
  • Supplemental complaint to implead private claimants (Cacho heirs, Landtrade, Azimuth) should be admitted.
  • Expropriation and reversion proceedings are distinct remedies; no forum shopping.
    Remanded: Civil Case 106 reinstated, supplemental complaint admitted, further proceedings ordered.

Expropriation Standards under Rule 67

A complaint must describe the land and join all owners, claimants, or occupants. Dismissal for non-joinder is improper; the court must allow impleader. If a party is omitted, the court may add them on motion, not by dismissing the action.

Quieting of Title Case (G.R. Nos. 178779, 178894)

Demetria C. Vidal and Azimuth petitioned to quiet title (Civil Case 4452), claiming Vidal sole heir of Doña Demetria. Teofilo Cacho, claiming heirship, and Landtrade intervened. RTC-Branch 3:

  • Jurisdiction proper under BP 129 § 19(2); personal jurisdiction by answer/intervention.
  • Under Rule 63, special proceeding for declaratory relief/quieting, heirship and title issues may be resolved together.
  • Vidal’s baptismal and genealogical evidence proved her lineage; Teofilo’s records contradicted his claim. Teofilo/Landtrade offered no evidence.
  • Quieted Vidal’s title (Civ. Code Arts. 476–481), enjoining Teofilo and assigns; awarded damages.

Court of Appeals affirmed on all grounds. The Supreme Court denied petitions, affirming both courts’ factual findings and legal conclusions. Quieting of title prescribes in 30 years (Civ. Code Art. 1141); Vidal filed within 20 years.

Ejectment Case—MTCC to RTC (G.R. No. 170505)

Landtrade obtained an MTCC ejectment judgment (Civil Case 11475-AF) against NAPOCOR/TRANSCO. RTC-Branch 5 granted Landtrade’s motion for execution pending appeal under Rule 70 § 19, because NAPOCOR/TRANSCO failed to post bond or deposit rent. Landtrade’s Rule 45 petition to enforce that order was rendered moot when RTC-Branch 1 affirmed MTCC judgment (Dec 12 2005) and the appeal advanced to the CA, where Rule 70 § 21 governs. The Supreme Court denied Landtrade’s petition as moot.

Supersedeas Bond and Exemptions

Rule 70 § 19 requires bond and deposits for MTCC-to-RTC appeal in ejectment. NAPOCOR Charter (RA 6395 § 13) formerly exempted filing fees, appeal bonds, supersedeas bonds; Court of Appeals held rent deposit likewise exempt due to ejusdem generis.

Ejectment Case—RTC to CA (G.R. Nos. 173355-56, 173563-64)

CA granted Landtrade execution pending appeal (RTC-Branch 1 decision) under Rule 70 § 21 but denied NAPOCOR/TRANSCO’s preliminary injunction. The Supreme Court granted certiorari, finding grave abuse:

  • Although Rule 70 § 21 allows immediate execution of RTC judgment, Rule 58’s preliminary injunction may still issue if justice so requires.
  • The power station and warehouse have long served essential public needs; execution would cause irreparable harm to power distribution and NAPOCOR/TRANSCO’s operations.
  • Issued preliminary injunction enjoining execution of RTC-Branch 1 Dec 12 2005 decision while appeal pending before CA; directed CA to promptly resolve appeals.

Cancellation of Titles and Reversion Case (G.R. No. 173401)

The Republic sued (Civil Case 6686) to cancel OCT Nos. 0-1200(a.f.), 0-1201(a.f.) and revert parcels, alleging certificates covered land beyond 1914 Cacho adjudication and failed to implement plan/deed conditions. RTC-Branch 4 dismissed for no cause of action, res judicata, prescription, and forum shopping. Supreme Court held:

  • Reversion suits under Public Land Act § 101 are proper when titles include publi
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