The Supreme Court denied the consolidated petitions of Azimuth International Development Corp., Demetria Confessor Vidal, and the Republic of the Philippines, and affirmed the Court of Appeals. The Court held that any claim exceeding the bounds of the judicial award finds no support in the controlling judgments, and that the excess portion of the larger parcel must revert to the mass of the public domain.
The Case
The petitions, filed under Rule 45 of the Rules of Court, assailed the Decision dated August 11, 2017 and the Resolution dated April 30, 2018 of the Court of Appeals in CA-G.R. CV No. 04083-MIN.
The subject of the petitions are two parcels of land located in what is now Sitio Nunucan, Barangay Suarez, Iligan City, but were originally part of Military Reservation No. 43, generally known as “Camp Overton.” In 1912, Demetria Cacho, predecessor-in-interest of Demetria Confessor Vidal, filed an Original Application for Registration over two parcels: lot 1 of Plan II-3732, with an area of 3,365 square meters or 0.36 hectare (the “smaller parcel”), docketed as GLRO Records No. 6908; and lot 2 of Plan II-3732, with an area of 378,707 square meters or 37.87 hectares (the “larger parcel”), GLRO Records No. 6909. The Government opposed the applications on the ground that the two parcels were properties of the United States and formed part of a military reservation.
Demetria claimed she purchased the smaller parcel from Gabriel Salzos, who bought it from a Moro woman named Alanga, married to Darondon. Alanga sold the smaller parcel without the consent of Darondon. The Land Registration Court found the smaller parcel to be the conjugal property of Alanga and Darondon, and ordered the presentation of a deed from Darondon renouncing his rights in favor of Demetria. For the larger parcel, which Demetria alleged she acquired from a Moro named Datto Bunglay through a Deed of Sale dated January 15, 1904, the LRC awarded only a portion in the southern part to Demetria, finding that 37.87 hectares is larger than what is cultivated ordinarily by Christian Filipinos.
The Issue
Vidal and Azimuth maintained that it is the land registration court that has the final say as regards the area to be awarded to Demetria, notwithstanding the final and executory 1912 LRC Ruling as affirmed in the Court's 1914 Decision, which determined with finality that Demetria is entitled only to the southern portion of the larger parcel. The question was whether Section 36 of Act No. 496 gave the land registration court the authority to amend that final award.
The Ruling
The Court found Vidal and Azimuth's reliance on Section 36 of Act No. 496 misplaced, holding that the provision pertains to the proceedings before the land registration court for an original application and does not refer to a dispute already adjudicated and elevated to the Court for confirmation. The Court ruled that the new survey mandated by the 1912 LRC Ruling and the 1914 Decision was intended only to segregate the land occupied by Datto Anandog from the rest of the larger parcel.
The Court declared that the excess portion of the larger parcel beyond the area awarded in the 1912 LRC Ruling, as affirmed in the 1914 Decision, must revert to the mass of the public domain. As to the smaller parcel under GLRO Records No. 6908, the Court held that irregularities standing alone do not warrant nullification, and that in the absence of competent proof of fraud, misrepresentation, or unlawful inclusion of property, no reversion may be decreed.
The dispositive portion reads: “ACCORDINGLY, the petitions filed by Azimuth International Development Corp. and Demetria Confessor Vidal in G.R. No. 239152 and the Republic of the Philippines in G.R. No. 239167, are DENIED.” The Court further ordered that the assailed Decision dated August 11, 2017 and the Resolution dated April 30, 2018 of the Court of Appeals in CA-G.R. CV No. 04083-MIN are AFFIRMED.
By the Numbers
- G.R. Nos. 239152 and 239167
- Smaller parcel: 3,365 square meters or 0.36 hectare (GLRO Records No. 6908)
- Larger parcel: 378,707 square meters or 37.87 hectares (GLRO Records No. 6909)
- 1912 LRC Ruling: December 10, 1912
- Deed of Sale for the larger parcel: January 15, 1904
- CA Decision: August 11, 2017; CA Resolution: April 30, 2018
- New survey ordered on or before the 30th day of March, 1913
The Court's Reasoning
The Court explained that Section 36 of Act No. 496 presupposes an application for registration at the level of the land registration court only, and does not cover a controversy already adjudicated and elevated to the Court. It reasoned that if the land registration court had authority to amend the final award, this would result in an unjustified modification and alteration of a final and executory decision as affirmed by the Court. The survey ordered was intended to segregate the portion adjudicated in favor of Demetria pursuant to the final and executory 1912 LRC Ruling.
On the smaller parcel, the Court held that while the LRC required the submission of a deed evidencing Darondon's relinquishment of his rights, the absence of that document, without more, does not warrant the nullification of the decree or the titles subsequently issued, absent competent proof of fraud, misrepresentation, or unlawful inclusion of property not covered by the LRC's adjudication.
This report is based on the Supreme Court decision in G.R. Nos. 239152 and 239167, penned by Associate Justice Ramon Paul L. Hernando.
This report summarizes a public Supreme Court decision and is not legal advice.