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ACTING REGISTRARS OF LAND TITLES v. RTC

FACTS:

The case involves a dispute over the ownership and possession of a 2,574-hectare parcel of land known as "Hacienda de Maricaban". The private respondent, Domingo Palomares, filed a suit for declaratory relief, quieting of title, and cancellation of certain land titles, claiming that the land was originally owned by Dolores Pascual Casal y Ochoa. The petitioners, on the other hand, argue that Dolores Casal's estate was not a juridical person authorized to bring the suit, and that the registration of the land titles had already been cancelled. The respondent judge, Francisco Velez, issued an order granting the private respondent's motion to perform acts of ownership over the land, including subdivision, sale, exchange, lease, or disposal of portions of the land. The respondent judge later issued a clarificatory order affirming the authority of the private respondent to execute the acts authorized in the previous order.

The petitioners question the validity of the respondent court's decision to decide the ownership and possession of the land in favor of the private respondent before trial. They also question the respondent court's authority to allow the private respondent to exercise acts of ownership and possession over the land before trial. The petitioners further argue that the respondent court lacked jurisdiction to hear and decide the case, and that it committed grave abuse of discretion in not dismissing the action or allowing the petitioners to appeal. The private respondent argues that the respondent court did not decide the case before trial and that the cancellation of OCT No. 291, the title to the land, was invalid. They also assert that the subsequent Transfer Certificates of Title (TCTs) issued are null and void. The private respondent also filed a manifestation stating that even if OCT No. 291 had been cancelled, the respondent judge had the authority to prevent landgrabbers from entering vacant portions of the land. The issues raised in the case are whether OCT No. 291 is still valid and subsisting and whether the respondent judge committed a grave abuse of discretion in issuing the orders in question. The court takes judicial notice that the land covered by TCT No. 192 (OCT No. 291) is government property based on certain proclamations and the cancellation of OCT No. 291.

ISSUES:

  1. Is OCT No. 291 still valid and subsisting?

  2. Did the respondent judge, in issuing the orders, dated October 12 and October 23, 1987, commit a grave abuse of discretion equivalent to lack or excess of jurisdiction?

  3. Whether the reconstitution of the lost duplicate owner's copy of OCT No. 291 is possible.

  4. Whether the cancellation of OCT No. 291 means that the title of the petitioner's ancestors to the property is invalid.

  5. Whether the present holders of the land are innocent purchasers for value.

  6. Whether the order of reconveyance was issued without notice and without trial or hearing.

  7. Whether the lower court erred in denying the Solicitor General's notice of appeal.

  8. Whether the petitioner is entitled to the relief demanded and if the injunction is justified.

  9. Whether the respondent judge violated the legal presumption that the possessor of a piece of land holds it under claim of ownership and with a just title.

  10. Whether the respondent judge should be administratively dealt with for his actions.

RULING:

  1. OCT No. 291 is not valid and subsisting. The Court takes judicial notice of the fact that the hectarage embraced by TCT No. 192 (OCT No. 291) consists of Government property. This is supported by Proclamation Nos. 192 and 423 which assert the ownership of the government over the said property. Additionally, OCT No. 291 has been duly cancelled and this cancellation was affirmed in previous court decisions.

  2. The respondent judge did not commit a grave abuse of discretion. The private respondent's claim that Judge Ostrand's decree was a counterfeit was not proven and is unsupported by the records. The presumption is that official duty has been regularly performed, and the burden is on the private respondent to prove irregular performance. Furthermore, the decision in AC-G.R. No. 00293 and G.R. No. 69834, which dismissed the private respondent's petition for the issuance of a new owner's copy of OCT No. 291, operates as the law of the case and confirms that the property covered by OCT No. 291 has been cancelled and ceded to the National Government.

  3. The reconstitution of the lost duplicate owner's copy of OCT No. 291 is not possible because the mother title has been duly cancelled.

  4. The cancellation of OCT No. 291 means that the title of the petitioner's ancestors to the property is invalid.

  5. The present holders of the land are considered innocent purchasers for value and reconveyance does not lie against them.

  6. The order of reconveyance was issued without notice and without trial or hearing, which constitutes grave abuse of discretion.

  7. The lower court erred in denying the Solicitor General's notice of appeal.

  8. The petition in G.R. No. 81564 is granted, making the writ of preliminary injunction permanent and declaring the cancellation of the Original Certificate of Title No. 291.

  9. The petition in G.R. No. 90176 is dismissed.

  10. The respondent judge is ordered to show cause why he should not be administratively dealt with for giving away property that belongs to the government, for blocking government efforts to defend its rights, and for filing comments without express leave of court.

PRINCIPLES:

  • The principle of regalian doctrine states that all lands of the public domain belong to the State and that ownership of land is vested exclusively in the State.

  • The principle of res judicata bars the instant proceedings as the previous court decisions dismissing the private respondent's petition and affirming the cancellation of OCT No. 291 operate as the law of the case.

  • The presumption of regularity of official duty applies, placing the burden on the party challenging the regularity to prove irregular performance.

  • Final judgment is conclusive not only on matters directly adjudicated but also as to any other matter that could have been raised in relation thereto.

  • Owners of property over which reconveyance is asserted are indispensable parties, without whom no relief is available and without whom the court can render no valid judgment.

  • Innocent purchasers for value are protected and reconveyance does not lie against them.

  • Injunction does not lie to take property out of the possession or control of one party and place it into that of another.

  • Notice and trial or hearing are required before issuing an order of reconveyance.

  • The legal presumption is that the possessor of a piece of land holds it under claim of ownership and with a just title.

  • Injunction is an extraordinary remedy that lies only in certain cases.

  • Trial judges should exercise caution in disposing of natural resources to private persons.