G.R. No. L-35644. September 30, 1975.
REPUBLIC OF THE PHILIPPINES, represented by the DIRECTOR OF THE COMMISSION OF PARKS AND WILDLIFE, petitioner, vs. HON. RAFAEL DE LA CRUZ, in his capacity as Judge of CFI Camarines Sur, Naga City, Branch III, ELVIRA C. MEDUA and the REGISTER OF DEEDS OF CAMARINES SUR, respondents.

FACTS

The Republic of the Philippines, through the Director of the Commission on Parks and Wildlife, filed a complaint for annulment of decree and reversion against Elvira C. Medua. The subject property is Lot 920 of the Pili Cadastre, covering approximately 1,839 hectares. The Republic alleged that this lot is actually designated as Lot 920-IR-317-D Forest Reserve, forming part of the inalienable public domain within the Mt. Isarog National Park. It contains critical water sources for Naga City and surrounding municipalities, telecommunication facilities, and forest lands. The lot was inadvertently included in cadastral proceedings, leading to a decision and decree issued in favor of Medua on March 1, 1972. The Republic contended the cadastral court lacked jurisdiction over inalienable land, rendering its decree void ab initio.
Respondent Medua moved to dismiss the complaint for lack of cause of action, arguing the alleged fraud was intrinsic, not extrinsic, and that the action was premature since no certificate of title had been issued. The respondent Court of First Instance, presided by Judge Rafael de la Cruz, granted the motion and dismissed the complaint. The court reasoned that the Republic should have pursued remedies within the cadastral proceedings and that there was no actual certificate of title to impugn. The Republic elevated the case to the Supreme Court via petition.

ISSUE

Whether the respondent court erred in dismissing the Republic’s complaint for annulment and reversion on the grounds of lack of cause of action.

RULING

Yes. The Supreme Court set aside the dismissal order and remanded the case for trial. The respondent court’s ruling was patently erroneous. The Republic’s complaint sufficiently alleged a cause of action. The core allegation was that the cadastral court never acquired jurisdiction over Lot 920 because it was part of a national park and forest reserve, constituting inalienable land of the public domain. Jurisdiction over the subject matter is conferred by law and cannot be conferred by the parties. If the land was indeed inalienable, the cadastral court had no authority to adjudicate it, making its decision and decree null and void from the beginning. An action to declare such a judgment void for lack of jurisdiction does not prescribe and is not barred by the one-year period for reviewing cadastral decrees.
The respondent court incorrectly focused on the absence of a issued certificate of title. The action targets the validity of the decree itself, which is the source of any potential title. The Republic’s right to seek reversion is inherent in its capacity as protector of the public domain. The Court cited analogous jurisprudence, including Republic vs. Court of Appeals and Juan, which held that titles issued over inalienable forest lands are void ab initio. Therefore, the complaint presented a valid cause of action warranting a full trial on the merits to determine the true character of the land. The preliminary injunction issued by the Supreme Court was ordered maintained pending final judgment.