G.R. No. 150327 ; June 18, 2003
REPUBLIC OF THE PHILS., et al., Petitioners, vs. MARILYN A. PERALTA, et al., and the Register of Deeds of Davao City, Respondents.

FACTS

Respondents, heirs of Benedicto Alonday, filed a complaint for recovery of possession and ownership against the Republic, represented by DENR officials. They claimed ownership over a parcel of land in Davao City by virtue of a Homestead Patent and a Transfer Certificate of Title. They alleged that in 1969, officers of the Bureau of Forest Development (BFD) entered a portion of the land, constructed a building, and later sought to install a generator without their consent. Petitioners, in their answer, asserted that the suit was against the State and that the occupied area was within the perimeter of the Mt. Apo National Park, a forest reserve under Proclamation No. 59, and not on alienable and disposable land.
The Regional Trial Court (RTC) commissioned a survey panel, which reported that a significant portion (145,682 sq. m.) of the land covered by the respondents’ title was within the Mt. Apo National Park reservation. Subsequently, the RTC, upon joint motion of the parties, declared no factual issues existed and decided the case based on pleadings. It ruled in favor of the respondents, ordering petitioners to vacate. The Court of Appeals upheld the RTC’s orders denying the petitioners’ motion for reconsideration and to reopen the trial for reception of evidence.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s decision which was rendered without trial and without receiving evidence on the critical factual issue of whether the subject property is part of a forest reserve.

RULING

Yes. The Supreme Court reversed the Court of Appeals and set aside the RTC orders. The Court held that the RTC committed a grave abuse of discretion in rendering judgment without trial. The core issue—whether the land occupied by the government was part of the alienable property covered by the respondents’ title or within the inalienable Mt. Apo National Park—was indisputably factual. The commissioners’ report itself created a pivotal factual controversy by finding that a large portion of the titled land was inside the forest reserve.
By deciding the case on the pleadings, the trial court effectively precluded the State from presenting evidence to prove that the occupied area was within the forest reservation, a matter of public interest involving the preservation of natural resources. The rule that a court may decide a case on the pleadings applies only when no factual issues exist. Here, a substantial factual issue was clearly present. The State’s right to due process was violated as it was denied the opportunity to substantiate its defense. The case was remanded to the RTC to reopen the trial and allow both parties to adduce their respective evidence.