G.R. No. 224610. October 13, 2021
VINES REALTY CORPORATION, PETITIONER, VS. RODEL RET, RESPONDENT.

FACTS

The subject property originally formed part of a 144.62-hectare land in Jose Panganiban, Camarines Norte, with mineral claims held by San Mauricio Mining Company (SMMC). SMMC transferred its surface rights to the government-owned National Shipyards and Steel Corporation (NASSCO) in 1957. By Proclamation No. 500 (1968), President Ferdinand E. Marcos reserved 170.2890 hectares, including the subject property, for NASSCO’s pier, warehouse, and smelting plant. On December 6, 1975, Presidential Decree No. 837 transferred ownership of the entire 170.2890 hectares to NASSCO, and Original Certificate of Title (OCT) No. 0-440 was issued in NASSCO’s name. On December 29, 1975, NASSCO sold the land to Philippine Smelters Corporation (PSC), a private corporation, and Transfer Certificate of Title (TCT) No. 13060 was issued to PSC. SMMC annotated an adverse claim on OCT No. 0-440, which was carried over to subsequent titles. PSC filed a quieting of title case (Civil Case No. 2882) against SMMC, resulting in a 1981 Supreme Court decision in SMMC v. Ancheta affirming PSC’s absolute ownership and ordering cancellation of SMMC’s adverse claim.
In 1986, PSC ceased operations. Petitioner Vines Realty Corporation (VRC), through Conrad C. Leviste, obtained a money judgment against PSC and, via execution, purchased portions of the property at public auction, eventually acquiring 93 hectares. Writs of possession and demolition were issued against informal settlers, but enforcement was repeatedly halted at the instance of local officials and settlers. The settlers, claiming to be tenants, filed DARAB Case No. 119-CN, which was dismissed for lack of merit and res judicata. Contempt charges against the settlers were upheld.
On April 7, 1999, respondent Rodel Ret and other informal settlers wrote to the Governor of Camarines Norte, alleging fraud in the issuance of OCT No. 0-440 and claiming possession since before World War II, with improvements like public streets, a plaza, chapel, school, and cemeteries. The Department of Environment and Natural Resources (DENR) ordered an investigation. Land Management Officer Fortunata Z. Hemady recommended reversion proceedings, citing that the land was alienable and disposable only in 1981, thus PD 837 and the titles derived from it were void. The DENR Secretary endorsed the case to the Office of the Solicitor General (OSG) for reversion. The OSG initially sought dismissal, arguing the land was already private due to PD 837 and the 1981 Supreme Court ruling. However, the DENR Secretary reiterated the directive for reversion. The OSG then filed a reversion petition before the Court of Appeals (CA). The CA, in its assailed Decision, ordered the OSG to review and reinvestigate for possible reversion, noting the land was still public domain when PD 837 was issued. VRC filed a motion for reconsideration, which was denied. VRC now assails the CA’s Decision and Resolution.

ISSUE

Whether the Court of Appeals erred in ordering the Office of the Solicitor General to review and reinvestigate the case for possible reversion proceedings on the subject property.

RULING

The Supreme Court granted the petition and reversed the Court of Appeals’ Decision and Resolution. The Court held that the subject property had already been adjudicated as private land in the final and executory 1981 decision in SMMC v. Ancheta, which affirmed PSC’s absolute ownership and settled the issue of title. This decision constitutes res judicata, barring any reversion proceedings. The Court emphasized that the power of control of the President over executive departments, including the DENR and OSG, does not extend to reviewing or overturning final judicial decisions. The OSG’s duty to initiate reversion proceedings under Commonwealth Act No. 141 (Public Land Act) applies only to lands of the public domain, not to properties already declared private by final judgment. The CA’s order for reinvestigation was an unwarranted interference with a settled judicial ruling. Thus, the Supreme Court reinstated the OSG’s earlier stance to dismiss the reversion case, upholding the finality of the 1981 ruling and VRC’s rights as successor-in-interest.