Case Summary (G.R. No. 230280)
Background of the Case
The case arises from a dispute over the ownership of two neighboring unregistered parcels of land: Lot No. 1024, sold to Susie Golez by Benito Bertuldo, and Lot No. 1025, which subsequent ownership claims are made by the heirs of Domingo Bertuldo. After various legal actions including a complaint for quieting of title and the involved parties opposing applications for land registration, the Department of Environment and Natural Resources (DENR) issued decisions that were ultimately challenged by the petitioners in the higher courts.
Legal Proceedings and Findings
In 2000, the Regional Trial Court (RTC) dismissed the Golezes' complaint for quieting of title for lack of merit, affirming that they owned Lot No. 1024 and not Lot No. 1025, a decision supported by the Court of Appeals (CA) and the Supreme Court. Respondents subsequently filed an application for free patent concerning Lot No. 1025, which petitioners opposed. The DENR initially ruled favorably towards petitioners but later modified this ruling in favor of respondents upon reconsideration, recognizing the prior ownership status confirmed by the courts.
Decision of the Court of Appeals
The Court of Appeals found the DENR's decisions to be void due to grave abuse of discretion. It highlighted that the DENR disregarded prior judicial findings, specifically those which affirmed the respondents' ownership of Lot No. 1025. It also noted that petitioners had committed forum shopping between their actions for quieting of title and their application for land registration, declaring the latter as invalid.
Disposition of the Supreme Court
The Supreme Court, in denying the petitioners' appeal, affirmed the CA's decision and resolution. It emphasized the improper acts of the petitioners in challenging the DENR’s resolutions and reiterated that the actions taken could not validly contradict established judicial findings. The Court also clar
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Case Citation
- 885 Phil. 318
- G.R. No. 230280
- Date: September 16, 2020
Parties Involved
- Petitioners: Spouses Rolando and Susie Golez
- Respondents: Heirs of Domingo Bertuldo (Genoveva Bertuldo, Erenita Bertuldo-Bernales, Florencio Bertuldo, Dominador Bertuldo, Rodel Bertuldo, Roger Bertuldo)
Procedural Background
- Petitioners filed a Petition for Review on Certiorari against the Court of Appeals' Decision dated July 20, 2016, and Resolution dated January 20, 2017.
- The Court of Appeals declared void the DENR's Decision dated April 28, 2011, and Resolution dated December 2, 2011, regarding the petitioners' application for free patent.
Antecedent Facts
- In 1976, Benito Bertuldo sold Lot No. 1024 to Asuncion Segovia on behalf of her daughter, Susie. The sale deed specified the property details.
- Petitioners constructed a house on Lot No. 1025, which is adjacent and unregistered, claiming it was on Lot No. 1024.
- Domingo Bertuldo, claiming ownership of Lot No. 1025, protested the construction. After his death, a relocation survey confirmed the house was on Lot No. 1025.
- Petitioners alleged that an amended deed corrected the original sale to reflect Lot No. 1025.
- Petitioners filed a Complaint for Quieting of Title regarding Lot No. 1025, which was dismissed by the RTC for lack of merit.
Key Judicial Findings
- The RTC's de