Case Summary (G.R. No. 187677)
Procedural History and Facts
On July 13, 2001, the DPWH filed a complaint for expropriation of several parcels, including the subject property. In 2002, the DPWH, through Engr. Patrick B. Gatan, reported the subject property as government land with the respondents' TCT alleged to be of dubious and fabricated origin. Consequently, the DPWH filed an amended complaint limiting the expropriation to the area ascertained based on the findings, claiming conflicting ownership. The RTC admitted the amended complaint, deferred release of the deposited compensation fund amounting to ₱18.4 million, and declared the subject property as one of “conflicting claims.”
During proceedings, respondents objected to the petitioner’s presentation of evidence challenging their title, citing Section 48 of Presidential Decree No. 1529 (P.D. 1529) which prohibits collateral attacks on Torrens titles. The RTC barred the petitioner from presenting evidence to attack the validity of respondents’ title, ruling that such issue must be raised only in a direct proceeding. The petitioner’s motion for reconsideration was denied. The respondents subsequently moved for the release of the deposited just compensation, which remains pending.
Issue Presented
The sole issue for resolution centers on whether the petitioner can be barred from presenting evidence questioning the validity of the respondents' Torrens title under TCT No. RT-11603 in the expropriation proceedings.
Applicable Law
- Section 9, Rule 67 of the Rules of Court (pertaining to uncertain ownership or conflicting claims in expropriation cases)
- Section 48 of Presidential Decree No. 1529 (the Property Registration Decree) prohibiting collateral attacks on Torrens titles
- Jurisprudence interpreting the scope and interplay of these provisions under the 1987 Philippine Constitution
Petitioner’s Arguments
The petitioner invokes Section 9, Rule 67, which authorizes the court in an expropriation proceeding to resolve issues of ownership if ownership is uncertain or conflicting claims exist. It contends that the amended complaint reflects the recognition of the respondents as mere claimants, with ownership uncertain. The petitioner relies on previous Supreme Court rulings that grant jurisdiction to the trial court in such proceedings to determine ownership for the specific purpose of just compensation. The petitioner asserts that such inquiry is a necessary incident to determine to whom compensation must be awarded and does not constitute a direct or collateral attack on the Torrens title.
Respondents’ Arguments
Respondents rely on Section 48 of P.D. 1529, asserting that the petitioner’s intent to introduce evidence to challenge their Torrens title constitutes a prohibited collateral attack. They argue that the title’s validity cannot be questioned except in a direct proceeding specifically instituted for that purpose, and thus the RTC correctly barred the petitioner from presenting ownership evidence.
Court’s Ruling: Interpretation of Section 9, Rule 67
The Court held that Section 9, Rule 67 allows the court hearing an expropriation case to entertain conflicting claims of ownership and to determine who is entitled to just compensation within the same proceeding. This power is grounded on the inherent right of the State to eminent domain, which includes not only taking possession but ensuring just compensation to the rightful owner.
Citing prior rulings, the Court explained that questions regarding ownership raised in expropriation proceedings are limited to identifying who should receive indemnity for the property taken. Such determinations are interlocutory and do not constitute a final adjudication of ownership or title. The Court analogized this to ejectment cases where ownership is temporarily determined for possession purposes but remains subject to normal rules on ownership litigation.
Court’s Ruling: Inapplicability of Section 48, P.D. 1529
The Court clarified that Section 48 of P.D. 1529 prohibits collateral attacks on Torrens certificates of title, which are indirect challenges aiming to nullify or annul the title outside direct proceedings. However, the Court distinguished that the petitioner’s presentation of evidence in this expropriation suit is not a collateral attack but a limited inquiry incident to determining just compensation under Section 9, Rule 67.
The amendment of the complaint to limit coverage to certain portions of the land and the RTC's declaration of conflicting claims signify recogniti
...continue readingCase Syllabus (G.R. No. 187677)
Background and Procedural History
- The petitioner, Republic of the Philippines through the DPWH, initiated an expropriation suit on July 13, 2001, against several defendants, including the private respondents, Spouses William and Rebecca Genato.
- The private respondents were registered owners of a 460-square meter parcel of land covered by Transfer Certificate of Title (TCT) No. RT-11603 (383648).
- During the proceedings, the DPWH received a report declaring the subject property as government land and suggesting that the respondents' title was of dubious origin and likely fabricated due to encroachment.
- Consequently, petitioner filed an Amended Complaint on June 24, 2002, to limit the property coverage in line with DPWH findings.
- Petitioner also filed a Manifestation and Motion on July 18, 2002, seeking to declare the property as of uncertain ownership or subject to conflicting claims.
- The Regional Trial Court (RTC) admitted the amended complaint, deferred releasing the compensation deposit of ₱18,400,000, and declared the property as one with conflicting claims through an order dated December 10, 2002.
- As petitioner presented evidence to establish ownership, respondents objected, asserting that petitioner was barred from attacking the validity of their Torrens title through collateral means.
- On July 12, 2005, the RTC barred petitioner from presenting evidence deemed to attack respondents' Torrens title, citing Section 48 of P.D. 1529.
- Petitioner filed a motion for reconsideration which was denied by the RTC on November 17, 2005.
- The respondents filed a motion on January 4, 2006, for payment of just compensation (₱20,700,000) and release of the deposited amount, which remained pending.
- Petitioner sought review from the Court of Appeals (CA) through a Petition for Certiorari in February 2006, which upheld the RTC's application of Section 48.
- Motions for reconsideration were denied by the CA, prompting petitioner’s timely appeal before the Supreme Court.
Issue Presented
- Whether petitioner may be barred from presenting evidence to contest the validity of the respondents’ title under TCT No. RT-11603 (383648) in the expropriation proceedings.
Petitioner’s Argument
- Petitioner cited Section 9, Rule 67 of the Rules of Court as empowering the expropriation court to determine ownership issues in the same proceeding when ownership is uncertain or there are conflicting claims.
- Cited jurisprudence (Republic v. Court of First Instance of Pampanga) supported the authority of the expropriation court to decide ownership issues.
- Argued the amended complaint recognized respondents as mere claimants with uncertain ownership desp