G.R. No. 224076, July 28, 2020
Republic of the Philippines, Petitioner, vs. Susan Datuin, Evelyn Dayot, Skylon Realty Corporation, Systematic Realty Incorporated, Baguio Pines Tower Corporation, Gold Land Realty Corporation, Good Harvest Realty Corporation, Parkland Realty and Development Corporation and the Register of Deeds of Nasugbu, Batangas, Respondents.

FACTS

The Republic of the Philippines, through the DENR and OSG, filed a Complaint for cancellation and reversion against the respondents. The petitioner sought the cancellation of various Original Certificates of Title (OCTs) and Transfer Certificates of Title (TCTs) and the reversion of the corresponding lots to the government. The basis was that the lots were inalienable, as established by a final judgment in Republic v. Ayalay Cia and/or Hacienda Calatagan, et al., and that fraud attended their transfer. The petitioner alleged that the land was originally covered by a Fishpond Lease Agreement (FLA) issued to Prudencia V. Conlu in 1987. This land was later subdivided and OCTs were issued to six individuals. These titles were later transferred, culminating in TCTs issued to several corporate respondents. The DENR found that the subdivision plan overlapped with the land covered by Conlu’s FLA and that the plan was not on its official file.
In their Answer, respondents Baguio Pines Tower Corporation and Systemic Realty, Inc. countered that the lots were classified as alienable and disposable as of May 14, 1969, long before the FLA was issued. They traced the land’s history to an Agricultural Sales Application filed in 1968, which was later converted to a Sales (Fishpond) Application. They also served a Request for Admission on the petitioner, which the petitioner failed to respond to. Consequently, they filed a Motion for Summary Judgment, arguing that the facts and documents in the Request for Admission were deemed admitted. They also presented a 2013 DENR Certificate of Verification stating the lots were agricultural and alienable as of June 29, 1987.
The trial court initially denied the motion for summary judgment, finding genuine issues of fact. Upon reconsideration, however, the trial court granted the motion and rendered a summary judgment dismissing the complaint. It ruled that the petitioner’s failure to respond to the Request for Admission resulted in implied admissions of the material facts and documents, leaving no genuine issue for trial. The Court of Appeals dismissed the petitioner’s subsequent petition for certiorari, ruling it was an improper remedy and that the trial court did not commit grave abuse of discretion. The Republic elevated the case to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari and in upholding the trial court’s grant of summary judgment in favor of the respondents.

RULING

Yes, the Court of Appeals erred. The Supreme Court granted the petition, reversed the Court of Appeals’ Resolutions, and set aside the trial court’s Orders granting summary judgment and dismissing the complaint. The case was remanded to the trial court for further proceedings.
The Supreme Court held that the trial court committed grave abuse of discretion in rendering summary judgment. A summary judgment is only proper when there is no genuine issue as to any material fact. In this case, genuine issues of fact existed. The core issue was the alienability of the land, which was squarely contested. The petitioner claimed it was inalienable based on a final Supreme Court ruling (Republic v. Ayalay), while the respondents claimed it was alienable based on a 1969 certification and a 2013 DENR verification. The trial court improperly relied on the petitioner’s implied admissions from the unanswered Request for Admission to resolve this central controversy. The matters subject of the Request for Admission went to the very heart of the case—the land’s classification and the validity of the titles—which are disputable and require evidentiary proof. The implied admission rule cannot be used to establish facts that are controversial or that relate to the central issue of the case. Furthermore, the trial court’s single order both granting reconsideration of the denial of summary judgment and then rendering summary judgment was procedurally flawed, as it deprived the petitioner of the opportunity to oppose the merits of the summary judgment motion after reconsideration was granted. The petitioner’s resort to a Rule 65 petition for certiorari before the Court of Appeals was the correct remedy to challenge the trial court’s grave abuse of discretion.