The case involved a land originally owned by Fermina Castro that was later subdivided and portions registered under the names of Jesus S. Yujuico and Augusto Y. Carpio. However, the land was later determined to fall under lands reclaimed by the government. The Republic filed a case to annul the decrees registering the land, claiming the land registration court did not have jurisdiction over inalienable public lands. The trial court dismissed the case. The Court of Appeals observed that shores are public domain properties not subject to private registration. However, the Supreme Court ruled that a reversion suit was no longer proper after almost three decades, and the rights of innocent purchasers should prevail over the government's interest
The case involved a land originally owned by Fermina Castro that was later subdivided and portions registered under the names of Jesus S. Yujuico and Augusto Y. Carpio. However, the land was later determined to fall under lands reclaimed by the government. The Republic filed a case to annul the decrees registering the land, claiming the land registration court did not have jurisdiction over inalienable public lands. The trial court dismissed the case. The Court of Appeals observed that shores are public domain properties not subject to private registration. However, the Supreme Court ruled that a reversion suit was no longer proper after almost three decades, and the rights of innocent purchasers should prevail over the government's interest
The case involved a land originally owned by Fermina Castro that was later subdivided and portions registered under the names of Jesus S. Yujuico and Augusto Y. Carpio. However, the land was later determined to fall under lands reclaimed by the government. The Republic filed a case to annul the decrees registering the land, claiming the land registration court did not have jurisdiction over inalienable public lands. The trial court dismissed the case. The Court of Appeals observed that shores are public domain properties not subject to private registration. However, the Supreme Court ruled that a reversion suit was no longer proper after almost three decades, and the rights of innocent purchasers should prevail over the government's interest
The case involved a land originally owned by Fermina Castro that was later subdivided and portions registered under the names of Jesus S. Yujuico and Augusto Y. Carpio. However, the land was later determined to fall under lands reclaimed by the government. The Republic filed a case to annul the decrees registering the land, claiming the land registration court did not have jurisdiction over inalienable public lands. The trial court dismissed the case. The Court of Appeals observed that shores are public domain properties not subject to private registration. However, the Supreme Court ruled that a reversion suit was no longer proper after almost three decades, and the rights of innocent purchasers should prevail over the government's interest
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1/ 2
G.R. No.
168661 October 26, 2007
ESTATE OF THE LATE JESUS S. YUJUICO, represented by ADMINISTRATORS BENEDICTO
V. YUJUICO and EDILBERTO V. YUJUICO; and AUGUSTO Y. CARPIO, Petitioners, vs. REPUBLIC OF THE PHILIPPINES and the COURT OF APPEALS, Respondents.
Facts:
A land originally owned by Fermina Castro (Decree No. N-150912) was sold to Jesus S. Yujuico who subdivided the land into two lots- one registered under his name and the other under the name of Augusto Y. Carpio.
By virtue of PD 1085, land reclaimed in the foreshore and offshore areas of Manila Bay became the properties of the Public Estates Authority (PEA), a government corporation that undertook the reclamation of lands or the acquisition of reclaimed lands. The PEA undertook the construction of the Manila Coastal Road. As this was being planned, a verification survey showed that the road directly overlapped the subject property, and that Yujuico and Carpio owned a portion of the land sold by the PEA to the Manila Bay Development Corporation.
A Complaint for Annulment and Cancellation of Decree No. N-150912 and its Derivative Titles was filed by the respondent against the petitioners alleging that (1) the land registered to Castro was still a portion of Manila Bay since it was still underwater thus, it could not be registered in the name of Fermina Castro; (2) the land registration court did not have jurisdiction to adjudicate inalienable lands, thus the decision adjudicating the subject parcel of land to Fermina Castro as well as the derivative titles of Yujuico and Carpio were void.
RTC dismissed the complaint. The CA observed that shores are properties of the public domain intended for public use and, therefore, not registrable and their inclusion in a certificate of title does not convert the same into properties of private ownership or confer title upon the registrant. Further, res judicata does not apply to lands of public domain, nor does possession of the land automatically divest the land of its public character.
Issue: Is a reversion suit proper in this case?
Ruling:
No, a reversion suit will no longer be allowed at this stage.
When the 1997 Rules of Civil Procedure became effective on July 1, 1997, it incorporated Rule 47 on annulment of judgments or final orders and resolutions of the RTCs. The two grounds for annulment under Sec. 2, Rule 47 are extrinsic fraud and lack of jurisdiction. If based on extrinsic fraud, the action must be filed within four (4) years from its discovery, and if based on lack of jurisdiction, before it is barred by laches or estoppel as provided by Section 3, Rule 47. Thus, effective July 1, 1997, any action for reversion of public land instituted by the Government was already covered by Rule 47.
The instant Civil Case No. 01-0222 for annulment and cancellation of Decree No. N-150912 and its derivative titles was filed with the Parañaque City RTC. It is clear therefore that the reversion suit was erroneously instituted in the Parañaque RTC and should have been dismissed for lack of jurisdiction. The proper court is the CA which is the body mandated by BP Blg. 129 and prescribed by Rule 47 to handle annulment of judgments of RTCs.
Assuming that the Parañaque RTC has jurisdiction over the reversion case, still the lapse of almost three decades in filing the instant case, the inexplicable lack of action of the Republic and the injury this would cause constrain us to rule for petitioners. While the general rule is that an action to recover lands of public domain is imprescriptible, said right can be barred by laches or estoppel. Section 32 of PD 1592 recognized the rights of an innocent purchaser for value over and above the interests of the government.
Insurance of Phil. Islands Corporation v. Spouses Gregorio GR No. 174104, February 14, 2011 "27 Yrs Na Ang Nakalipas, Ngayon Ka Lang Nagreklamo NG Fraud!" Prescription v. Laches
