G.R. Nos. 162335 & 162605; March 6, 2012
SEVERINO M. MANOTOK IV, ET AL., Petitioners, vs. HEIRS OF HOMER L. BARQUE, represented by TERESITA BARQUE HERNANDEZ, Respondents.

FACTS

This case involves conflicting claims over Lot 823 of the Piedad Estate in Quezon City. The Manotok family asserted ownership based on a Transfer Certificate of Title (TCT) derived from a 1923 Sale Certificate and a subsequent Deed of Conveyance from the government under the Friar Lands Act. The Barques filed a petition for administrative reconstitution of a purported lost title over the same lot. The Land Registration Authority denied the Barques’ petition, a decision affirmed by the Court of Appeals. Upon review, however, the Supreme Court, in a 2010 Decision, nullified the titles of both the Manotoks and the Barques and declared the lot as belonging to the National Government.
The Manotoks and Barques filed separate motions for reconsideration. The Manotoks argued that it was unjust to divest them of property long held under a registered title based on the assumed absence of a ministerial approval on the original deeds. They contended that the Court introduced a reversion issue not originally pleaded, depriving them of due process, and that the case was improperly converted from a simple reconstitution appeal into an ownership dispute decided without a trial of first instance.

ISSUE

The core issue is whether the Supreme Court’s 2010 Decision, which nullified the titles and declared the property as government-owned, should be reconsidered on grounds of due process and substantive errors regarding the validity of the Manotoks’ title under the Friar Lands Act.

RULING

The Court denied the motions for reconsideration and affirmed its prior Decision. On due process, the Court held that the Manotoks were not deprived of their right to be heard. The issue of the validity of their title was central to the reconstitution case, as the Barques’ claim directly challenged it. The Court’s directive for the Court of Appeals to receive evidence was a proper exercise of its constitutional power to review, and the parties fully participated in that proceeding.
On the substantive validity of the title, the Court reiterated that under Section 18 of the Friar Lands Act (Act No. 1120), no sale of friar land is valid without the approval of the Secretary of the Interior (later Agriculture and Natural Resources). The Manotoks failed to present conclusive evidence that Deed of Conveyance No. 29204 contained this mandatory Secretary’s approval. The absence of this approval rendered the sale void ab initio. Consequently, the TCT issued to the Manotoks was also void, as it originated from a legally ineffective transaction. The Court rejected the argument that DENR Memorandum Order No. 16-05, which sought to ratify defective deeds, could cure this fundamental flaw, as an administrative order cannot validate a transaction void from the beginning. The lot therefore reverted to the public domain, subject to a proper reversion suit by the State.