G.R. No. 191590, April 21, 2014
Republic of the Philippines, Petitioner, vs. Transunion Corporation, Respondent.

FACTS

Leticia Salamat filed an Application to Purchase Friar Lands (Lot No. 5741) with the DENR-CENRO. Her application was indorsed to the Land Management Bureau (LMB). Salamat later discovered the lot was already covered by TCT No. T-616740 in the name of Transunion Corporation. Salamat filed a Protest with the LMB (LMB Case No. 114), alleging the title was obtained through fraud and that her family had been in continuous possession. The LMB OIC-Director issued a Special Order designating Atty. Rogelio C. Mandar to conduct a formal investigation pursuant to Lands Office Circular No. 68 (LC 68). Transunion filed a motion to dismiss the protest, which was denied. After investigation, Atty. Mandar issued an investigation report recommending that steps be taken before a competent court for the annulment of the title and reversion of the lot to the government. This recommendation was adopted by the LMB Legal Division and approved by the LMB Director. Neither Salamat nor Transunion were furnished copies of this report or memorandum. The DENR transmitted the records to the Office of the Solicitor General (OSG), which then filed a complaint for cancellation of title and/or reversion (Civil Case No. 2085-08) against Transunion before the RTC. Transunion filed a Motion to Dismiss, arguing the complaint was premature due to the LMB’s failure to notify it of the investigation report, depriving it of the opportunity to seek reconsideration or appeal, and thus constituting a failure to exhaust administrative remedies and a complaint stating no cause of action. The RTC denied the motion to dismiss. The CA reversed the RTC, granting Transunion’s petition for certiorari, ruling the filing of the reversion complaint was premature due to failure to exhaust administrative remedies.

ISSUE

Whether or not the CA correctly granted Transunion’s petition for certiorari against the RTC’s order denying the latter’s motion to dismiss.

RULING

The Supreme Court ruled that the petition is meritorious. It held that the RTC did not commit grave abuse of discretion in denying the motion to dismiss. The investigation conducted by the LMB under LC 68 was merely investigative and fact-finding/recommendatory in nature, meant only to determine whether the LMB Director should initiate reversion proceedings. The investigation report was not a decision or order of the Regional Executive Director subject to reconsideration or appeal. Section 15 of LC 68, governing the report of investigation, does not provide for remedies of reconsideration or appeal. Therefore, further reconsideration or appeal of the investigation report was not a condition precedent to the filing of the reversion complaint. Consequently, there was no violation of the rule on exhaustion of administrative remedies, and the reversion complaint stated a cause of action. The CA decision was reversed and set aside.