G.R. No. 215671 September 19, 2018
Alsons Development and Investment Corporation, Petitioner vs. The Heirs of Romeo D. Confesor, and The Honorable Office of the President, Respondents

FACTS

Petitioner Alsons Development held an Industrial Forest Plantation Management Agreement (IFPMA) with the DENR over a 899-hectare parcel of land in General Santos City. The Heirs of Romeo Confesor filed a protest with the DENR seeking the cancellation of the IFPMA, asserting that a large portion of the land was covered by their Original Certificate of Title (OCT) No. V-1344, and was therefore private property beyond the DENR’s jurisdiction to lease. The DENR initially dismissed the protest, finding the heirs guilty of laches for not asserting their claim earlier against Alsons’ predecessors-in-interest. The Office of the President (OP) reversed the DENR, upholding the Torrens title and ordering the IFPMA’s cancellation, but later reinstated the DENR’s dismissal upon reconsideration, only to reverse itself again and finally order the IFPMA’s cancellation.
While the administrative protest was pending, a separate civil action for annulment of title and reversion (Civil Case No. 8374) was filed by the Republic against the Confesor heirs before the Regional Trial Court (RTC) of General Santos City, directly challenging the validity of OCT No. V-1344. The CA affirmed the OP’s final order cancelling the IFPMA. Alsons appealed to the Supreme Court.

ISSUE

Whether the Office of the President and the Court of Appeals erred in ordering the cancellation of IFPMA No. 21 based on a determination of the validity of a Torrens title, while a direct action challenging that very title was pending in court.

RULING

The Supreme Court GRANTED the petition, REVERSED the CA, and ordered the dismissal of the administrative protest. The core legal logic is premised on the doctrine of judicial stability or non-interference, and the principle that a Torrens title can only be challenged in a direct action before the proper courts. The OP and the CA overstepped their authority by making a definitive ruling on the validity and authenticity of OCT No. V-1344 in an administrative proceeding. Such a determination is a judicial function reserved for the courts in a direct attack, such as the pending reversion case (Civil Case No. 8374). The administrative agencies, in resolving the protest over the IFPMA, improperly assumed jurisdiction to adjudicate the fundamental issue of land ownership, which was already sub judice before the RTC.
The Court emphasized that where the rights of parties in one action cannot be properly determined until the questions raised in another pending action are settled, the former should be stayed to avoid conflicting decisions. The propriety of cancelling the IFPMA was entirely dependent on the resolution of the title’s validity. Therefore, it was premature for the OP and the CA to order the IFPMA’s cancellation based on their own assessment of the title. The correct course was to dismiss the administrative protest without prejudice to the outcome of the judicial reversion case. The RTC, in the direct action, is the proper forum to conclusively settle the issue of whether the land is public (supporting the IFPMA) or private (belonging to the heirs).