GR 130906; (February, 1999) (Digest)
G.R. No. 130906 February 11, 1999
REPUBLIC OF THE PHILIPPINES, represented by the DIRECTOR, LANDS MANAGEMENT BUREAU, petitioner, vs. FELIX S. IMPERIAL JR., FELIZA S. IMPERIAL, ELIAS S. IMPERIAL, MIRIAM S. IMPERIAL, LOLITA ALCAZAR, SALVADOR ALCAZAR, EANCRA CORPORATION, and the REGISTER OF DEEDS of LEGASPI CITY, respondents.
FACTS
The Republic, through the Director of the Lands Management Bureau, filed a complaint for reversion against the respondents, seeking to cancel their Transfer Certificates of Title and revert the lots to the public domain. The titles were derived from Original Certificate of Title (OCT) No. 408 (500) issued in 1917 to the late Elias Imperial. The petitioner alleged that the land is foreshore land, based on a 1994 DENR Region V investigation finding it had features like mangroves, permanent seawater submersion, and being non-alienable public land.
The respondents moved to dismiss, arguing the decree of registration from the 1917 cadastral proceedings had long become incontrovertible, the OCT was judicially reconstituted in 1953, and a 1983 administrative finding by the Director of Lands stated the land was not foreshore. The Regional Trial Court (RTC) dismissed the complaint. The petitioner appealed to the Court of Appeals but failed to file its appellant’s brief on time despite several extensions. The CA dismissed the appeal for failure to file the brief.
ISSUE
Whether the Court of Appeals gravely abused its discretion in dismissing the petitioner’s appeal for failure to file the appellant’s brief within the extended period.
RULING
Yes. The Supreme Court granted the petition, setting aside the CA’s resolutions and reinstating the appeal. The Court ruled that while procedural rules on reglementary periods are mandatory, they may be relaxed for persuasive and compelling reasons to serve substantial justice. This case presents such an exception due to the paramount public interest involved.
The core issue—whether the land is foreshore and thus inalienable—remains unresolved due to contradictory findings. The 1983 opinion of the Director of Lands stated the land was not part of the foreshore, while the 1994 DENR Region V investigation concluded it was. This contradiction, not resolved by the RTC, prevents a conclusive classification. Determining the true nature of land claimed to be part of the public domain is a matter of great public interest, as it involves the State’s duty to preserve its patrimony. The State’s appeal, which raises a significant legal question over the ownership and alienability of the land, constitutes good and sufficient cause to relax procedural rules. The appeal was thus reinstated and remanded to the CA for further proceedings.