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ALBERTO G. PINLAC v. CA

FACTS:

The case involves a Petition for Quieting of Title filed by the petitioners, who claimed ownership over three parcels of land. The trial court initially ruled in favor of the petitioners, declaring them as absolute owners of the lots and ordering the cancellation of certain certificates of title. However, the defaulted title owners of Vilma Subdivision filed a Petition to Annul the Partial Decision, which was granted by the Court of Appeals. The Court of Appeals held that the trial court did not acquire jurisdiction over the respondents due to defective service of summons.

The petitioners then filed a petition for certiorari with the Supreme Court, seeking to reverse the decision of the Court of Appeals. The Supreme Court, however, denied the petition and affirmed the decision of the Court of Appeals. Dissatisfied, the petitioners filed a Motion for Reconsideration, arguing that the trial court's disposition regarding Lot No. 3 should not have been annulled.

The Supreme Court partially granted the motion for reconsideration, reinstating certain paragraphs of the Partial Decision pertaining to Lot No. 3. Meanwhile, the Republic of the Philippines, represented by the Land Registration Authority, filed a Motion for Intervention and a Petition-In-Intervention. The Republic sought the declaration of the validity of the title and the nullity of the proceedings in Civil Case No. Q-35673, among other reliefs.

In the dispute over the ownership and possession of the parcel of land, the petitioners sought to intervene in the case. They argued that they had a substantial interest in the subject property, and their rights were disregarded when the trial court granted the respondent's petition for prohibition with injunction without impleading them as parties. The trial court, however, denied their motion to intervene, citing the technicalities of the rules on intervention and petition for relief from judgment.

The petitioners argued that the denial of their motion was an injustice and asserted that their substantial interest in the property made them indispensable parties. They also contended that procedural rules should facilitate the application of justice and not hinder or delay it. The Solicitor General supported the petitioners' position, asserting that the Republic had an interest in the property as it had been reserved for the national government center site.

ISSUES:

  1. Whether paragraphs 4 and 5 of the trial court's Partial Decision, which declared certain portions of Lot No.3 null and void without specifying the exact areas and the classification of defaulted and non-defaulted respondents, violated the constitutional mandate that decisions should clearly state the facts and the law on which it is based.

  2. Whether OCT No. 333, the original title covering Lot No. 3, is valid and existing.

  3. Whether the chief Executive or President of the Philippines has the power to classify lands of the public domain into mineral, timber, and agricultural.

  4. Whether the land in question should be classified as forest land.

  5. Whether the OCT No. 333 and TCTs derived from it are legal and valid.

  6. Whether there is a conflict between the decisions of the Court of Appeals regarding the ownership of Lot Nos. 1, 2, and 3.

  7. Whether the decision of the Regional Trial Court declaring petitioners as absolute owners of Lot Nos. 2 and 3 is valid.

RULING:

  1. Paragraphs 4 and 5 of the trial court's Partial Decision are null and void for failing to clearly specify the portions of Lot No. 3 that are in excess of its true area and the distinction between defaulted and non-defaulted respondents. This violation of the constitutional mandate requires the modification of the November 20, 2001 resolution reinstating the said paragraphs.

  2. OCT No. 333, the original title covering Lot No. 3, is valid and existing since it was issued by the Land Registration Court after a fair trial and in accordance with the requirements of the law. The Republic, having failed to appeal the decision in Republic v. Tofemi Realty Corporation, which upheld the validity of OCT No. 333, cannot dispute its validity.

  3. The court ruled that based on previous cases, there was no legal provision vesting in the chief Executive or President of the Philippines the power to classify lands of the public domain into mineral, timber, and agricultural. The courts were therefore invested with the power to make corresponding classifications in justiciable cases.

  4. The court held that the land in question should not be declared as forest land because the record does not reveal that the Government has always considered the lot as a forest reserve, and to declare it as forest land would deprive the defendants of their registered property without due process of law.

  5. The court declared that OCT No. 333 is legal and valid, and consequently, the TCTs derived from it are also legal and valid. However, the court stated that the metes and bounds of the land covered by OCT No. 333 were not specified in the decision of the Court of Appeals, so they cannot adopt the findings as to the area of OCT No. 333. Additionally, the court held that the entire Partial Decision of the trial court cannot be nullified, as the defaulted defendants in Lot No. 1 did not question the decision, and it was not shown that the OSG is an indispensable party to Lot No. 1.

  6. There is no conflict between the decisions of the Court of Appeals. The decision in CA-G.R. SP No. 17221 only granted the substitution of the World War Veterans Legionaries of the Philippines (WW II) for its individual members who were declared as owners of Lot Nos. 1, 2, and 3 in the Partial Decision. The decision in CA-G.R. SP No. 17596 set aside the Partial Decision, but it did not affect the prayer for substitution.

  7. The decision of the Regional Trial Court declaring petitioners as absolute owners of Lot Nos. 2 and 3 is void. Paragraph 1 of the dispositive portion of the decision is annulled insofar as it declares petitioners as absolute owners.

PRINCIPLES:

  • Decisions should clearly and distinctly state the facts and the law on which they are based, in compliance with the constitutional mandate.

  • Titles duly issued by the Land Registration Court, after a fair trial and in accordance with the law, are considered valid and existing.

  • The court follows the principle of stare decisis, which means that once a principle of law applicable to a certain set of facts has been laid down by the court, it must adhere to such principle and apply it to all future cases with substantially the same facts.

  • The court applies the presumption that land is agricultural in nature in the absence of contrary evidence, as it is beneficial for the Philippines to have a large public domain come under private ownership.

  • Depriving individuals of their registered property without due process of law violates their rights.

  • A decision granting substitution does not contradict a decision setting aside a partial decision.

  • A void decision is not valid and has no legal effect.