G.R. No. L-27006 June 30, 1970
REPUBLIC OF THE PHILIPPINES, petitioner, vs. COURT OF FIRST INSTANCE OF PAMPANGA, presided formerly by Judge L. Pasicolan, and now by Judge Andres C. Aguilar, the spouses FRANCISCO ROQUE and FRANCISCA HENSON, and the spouses JUAN PUNZALAN and EUFROSINA WINGCO, respondents.

FACTS

The Republic of the Philippines filed an expropriation case for the Henson Estate, which had been partitioned among heirs. One lot, Lot No. 6, Block 6, was assigned to defendant Francisca Henson-Roque. After the case was filed, Antonio Feliciano, claiming ownership of the lot via a sale from Henson-Roque, intervened. The court declared that sale null and void for violating the Land Reform Act, as it occurred after the expropriation filing, and ordered the cancellation of Feliciano’s title. However, before that order, Feliciano had sold the same lot to the spouses Juan Punzalan and Eufrosina Wingco, who obtained a new certificate of title. The lower court initially hesitated, suggesting a separate action to determine the validity of the sale to the Punzalans and their title. After a settlement between the Republic and the original heirs, the court issued an order of condemnation. The defendants later sought to exclude several lots, including Lot No. 6, claiming they were sold to third parties. The court’s stance fluctuated, eventually ordering the lot’s re-inclusion and declaring that issues of sales validity and title cancellation should be determined. After the government failed to initiate a separate action as directed, the Punzalans moved for exclusion again. The court initially declared it had authority to resolve the issue under the Rules but later, under a reassigned judge, disavowed jurisdiction and ordered the lot’s exclusion from condemnation. The Republic’s motion for reconsideration was denied, leading to this certiorari petition.

ISSUE

Whether or not the court hearing the expropriation case has jurisdiction to determine, in the same proceeding, the issue of ownership of the land sought to be condemned.

RULING

Yes. The court has jurisdiction to determine conflicting claims of ownership in the same expropriation proceeding. Section 9 of the Revised Rule 69 (now Rule 67) explicitly provides that if ownership is uncertain or there are conflicting claims, the court may order compensation paid to the clerk for the benefit of persons adjudged entitled in the same proceeding. To determine who must be indemnified for Lot No. 6, the court must necessarily rule on the validity of the sale to the Punzalan spouses. This power includes the authority to order the cancellation of certificates of title if evidence warrants, as such an order would be a necessary consequence of determining rightful ownership and does not constitute a reopening of the land registration proceeding. Requiring a separate action would lead to multiplicity of suits, unnecessary complication, and duplication of proceedings, such as reappointing commissioners of appraisal. The writ of certiorari is granted, the respondent court’s order disavowing jurisdiction is reversed and set aside, and the case is remanded for further proceedings.