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ALBERTO G. PINLAC v. CA

FACTS:

The case at hand involves a dispute over a sizable piece of real property located in Old Balara, Sitio Veterans, Barrio Payatas, and Silangan, Quezon City. The petitioners, who are World War II veterans, their dependents, and successors-in-interest, filed a class suit for Quieting of Title before the Regional Trial Court of Quezon City. They argue that the property, totaling 502 hectares, was part of government-owned forest lands. The petitioners assert that they and their predecessors-in-interest have continuously, adversely, and exclusively occupied the property for over 30 years, and have applied for land titling with the appropriate government agency. Due to difficulties in serving summons personally, the court granted petitioners' motion to serve summons by publication. Some of the named respondents filed responsive pleadings, while Vil-Ma and others failed to answer and were declared in default. The trial court found certain facts to be conclusive, including the existence of three parcels of land within the disputed property, irregularities in the titles of these parcels, and the issuance of numerous transfer certificates of title without proper documentation or cancellation of existing titles.

The disputed lots, Lots 1, 2, and 3, are covered by OCT No. 614, TCT No. 5690, and TCT No. 3548 respectively. These titles do not have technical descriptions on their respective face, rendering them null and void. The Bureau of Forest Development certified that the lots are part of unclassified public forest land belonging to the government. However, the petitioners have been in continuous, public, open, and uninterrupted possession of the lots for 30 years. The Bureau of Forest Development had knowledge of and encouraged the petitioners' occupancy and even issued residential permits to some of them. The court a quo rendered a Partial Decision in favor of the petitioners, declaring them as the absolute owners of Lots 1, 2, and 3 through extraordinary prescription. The court also declared the nullity of the titles issued from the void titles and ordered the cancellation of these titles from the Register of Deeds of Quezon City. The court further ordered the cancellation of the excess area in TCT No. 333 and subsequent titles issued based on it.

In a Petition for Annulment of Judgment, the titled owners of subdivided lots within Vil-Ma contested a default judgment rendered by the trial court in Civil Case No. Q-35672. They argued that the court had no jurisdiction over them and their properties, as they were not made parties in the case. They further alleged that the Partial Decision against the defaulted respondents was null and void due to lack of jurisdiction and extrinsic fraud. They asserted that the trial court violated their right to due process and that their registered titles cannot be defeated by adverse possession. They also claimed that the trial court had no authority to reclassify the subject property as agricultural land since it was originally unclassified forest land. Additionally, they argued that the trial court erred in rendering the mother title (OCT No. 614) null and void, as it had been declared valid and legal by the Supreme Court in a previous case.

ISSUES:

  1. Whether or not the Court of Appeals' Decision violated petitioners' right to due process by not addressing all the issues raised in the answer filed by petitioners.

  2. Whether or not the trial court acquired jurisdiction over Vilma Maloles Subdivision through the publication of the summons and petition as ordered by the trial court and whether the Partial Decision was legal, valid, and proper.

  3. Whether or not the private respondents had a valid cause of action, given the contradictory positions or theories of the case they adopted.

RULING:

  1. The Supreme Court found no merit in the petition and determined that the Court of Appeals did not violate the petitioners' right to due process. The Court of Appeals need not retry the facts but only needed to resolve the issues of lack of jurisdiction, existence of extrinsic fraud, and denial of due process of law. The action for annulment of judgment is not a substitute for the lost remedy of appeal.

  2. The Supreme Court agreed with the Court of Appeals' conclusion that the Partial Decision was null and void insofar as the private respondents were concerned. This was due to the fact that the individual lot owners were not properly served summons or notified of the proceedings, as the publication was done in a local newspaper not of general circulation in Quezon City. Additionally, the Vilma Maloles Subdivision had already been dissolved as a juridical entity, and thus could not be sued.

  3. The Supreme Court found that the private respondents did have a valid cause of action as they were not duly informed of the case's proceedings, thereby violating their right to due process. The court emphasized that without proper service and notification, the trial court could not have acquired jurisdiction over them.

PRINCIPLES:

  • Due Process: Before a party can be deprived of rights or property, they must be informed of the claim against them and given an opportunity to present their case.

  • Jurisdiction: Proper and effective service of summons is crucial for the court to acquire jurisdiction over the parties involved.

  • Service of Summons by Publication: For service by publication to be effective, it must be done in a newspaper of general circulation and comply strictly with the requirements set by the rules.

  • Effect of Default Judgments: Default judgments are generally disfavored and are not based on the merits of the case. They must nonetheless comply with procedural requirements.

  • Partial Judgment in Cases of Multiple Respondents: When a case states a common cause of action against multiple respondents, the court should try the case against all respondents based on the answers filed, even those who have defaulted.

  • Annulment of Judgment: Grounds for annulment include extrinsic fraud and lack of jurisdiction. The aim is to renew litigation where a final judgment was flawed procedurally.

  • Legal Presumption of Land Classification: Land is presumed agricultural unless there is substantial proof to classify it otherwise based on its more valuable purpose.