CASE 2012-0075: REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE REGIONAL EXECUTIVE DIRECTOR OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, REGIONAL OFFICE NO. 3 VS. ROMAN CATHOLIC ARCHBISHOP OF MANILA; SAMAHANG KABUHAYAN NG SAN LORENZO KKK, INC., REPRESENTED BY ITS VICE PRESIDENT ZENAIDATURLA VS. ROMAN CATHOLIC ARHBISHOP OF MANILA (G.R. NO. 192975/ G.R. NO. 192975, 12 NOVEMBER 2012, PERLAS-BERNABE, J.) SUBJECT/S: MOTION TO DISMISS; EQUITABLE ESTOPPEL; REVERSION SUITS. (BRIEF TITLE: REPUBLIC VS. ROMAN CATHOLIC ARCHBISHOP OF MANILA).
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SUBJECTS/DOCTRINES/DIGESTS:
THE REPUBLIC FILED A CASE FOR ANNULMENT OF CERTAIN TITLES BELONGING TO THE ROMAN CATHOLIC ARCHBISHOP OF MANILA (RCAM) AND TO CERTAIN INDIVIDUALS WHICH PURCHASED SUBJECT LOTS FROM THE RCAM.
RCAM MOVED TO DISMISS SINCE THE SUBJECT LOTS WERE GRANTED TO RCAM BY VIRTUE OF A DECISION OF AN RTC ACTING AS LAND REGISTRATION COURT AND THE RTC CANNOT ANNUL A JUDGEMENT OF ANOTHER RTC. TRIAL COURT DENIED MOTION TO DISMISS. CA REVERSED TRIAL COURT’S ORDER ON THE GROUND THAT THE CASE SHOULD BE FILED AT CA SINCE IT (CA) ALONE CAN INVALIDATE RTC JUDGMENT. FURTHERMORE, THE STATE IS IN ESTOPPEL FOR NOT TAKING ACTION AFTER SO LONG A PERIOD OF TIME.
DOES RTC HAVE JURISDICTION OVER THE CASE?
YES.
IT IS AXIOMATIC THAT THE NATURE OF AN ACTION AND WHETHER THE TRIBUNAL HAS JURISDICTION OVER SUCH ACTION ARE TO BE DETERMINED FROM THE MATERIAL ALLEGATIONS OF THE COMPLAINT, THE LAW IN FORCE AT THE TIME THE COMPLAINT IS FILED, AND THE CHARACTER OF THE RELIEF SOUGHT IRRESPECTIVE OF WHETHER THE PLAINTIFF IS ENTITLED TO ALL OR SOME OF THE CLAIMS AVERRED.
THE MATERIAL AVERMENTS, AS WELL AS THE CHARACTER OF THE RELIEF PRAYED FOR BY PETITIONERS IN THE COMPLAINT BEFORE THE RTC, SHOW THAT THEIR ACTION IS ONE FOR CANCELLATION OF TITLES AND REVERSION, NOT FOR ANNULMENT OF JUDGMENT OF THE RTC. THE COMPLAINT ALLEGED THAT LOT NOS. 43 TO 50, THE PARCELS OF LAND SUBJECT MATTER OF THE ACTION, WERE NOT THE SUBJECT OF THE CFI’S JUDGMENT IN THE RELEVANT PRIOR LAND REGISTRATION CASE. HENCE, PETITIONERS PRAY THAT THE CERTIFICATES OF TITLE OF RCAM BE CANCELLED WHICH WILL NOT NECESSITATE THE ANNULMENT OF SAID JUDGMENT.
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THE CA APPLIED EQUITABLE ESTOPPEL AGAINST THE STATE AND CONSIDERED IT BARRED FROM FILING A REVERSION SUIT. IT EXPLAINED THAT THE LOTS WERE ALREADY ALIENATED TO INNOCENT PURCHASERS FOR VALUE AND THE STATE FAILED TO TAKE ACTION TO CONTEST THE TITLE FOR AN UNREASONABLE LENGTH OF TIME. HENCE, THE CA ORDERED THE RTC TO GRANT RCAM’S MOTION TO DISMISS. WAS CA CORRECT?
NO.
IT IS PREMATURE AT THIS STAGE TO APPLY THE DOCTRINE OF EQUITABLE ESTOPPEL BECAUSE THE PARTIES HAVE NOT YET PRESENTED ANY EVIDENCE THAT WOULD SUPPORT SUCH FINDING.
TO READ THE DECISION JUST DOWNLOAD THE FILE BELOW.
J.A.B. Bulao & Associates 