G.R. No. 231001 , March 24, 2021
Constantino Y. Belizario, Petitioner, vs. Department of Environment and Natural Resources and the Registry of Deeds of Nasugbu, Batangas, Respondents.

FACTS

On May 12, 1960, the Republic of the Philippines filed a complaint for annulment of titles against Ayala y Cia and others (Ayalas) before the Court of First Instance (CFI) of Batangas, docketed as Civil Case No. 373. The Republic alleged that the Ayalas’ titles illegally included portions of territorial waters and public domain lands, increasing the original area of Hacienda Calatagan from 9,652.583 hectares (covered by TCT No. 722) to 12,000 hectares. On June 2, 1962, the CFI rendered a decision declaring TCT No. T-9550 and other subdivision titles issued over areas outside the private land covered by TCT No. 722 as null and void, and reverting those areas to public dominion. This decision was affirmed with modification by the Supreme Court in G.R. No. L-20950 on May 31, 1965, which found that the excess area of 2,000 hectares consisted of public domain lands. Due to non-execution, the Supreme Court, in subsequent resolutions (e.g., G.R. No. L-30420 on March 25, 1988 and a Resolution dated October 6, 2008), directed the immediate execution and nullification of all derivative titles over the excess areas, emphasizing that the relocation survey ordered was merely a tool to prevent error in execution and not a basis for relitigation.
On September 17, 1987, petitioner Constantino Y. Belizario purchased a 24,961-square meter parcel of land in Calatagan, Batangas from the Department of Agrarian Reform (DAR), and TCT No. T-51621 was issued in his name. On July 12, 2011, petitioner received an Order from the Regional Trial Court (RTC) of Balayan, Batangas, Branch 10, dated June 28, 2011, directing the cancellation of his TCT No. T-51621. This was based on a report from a Technical Working Committee (TWC) created by the DENR, which found that the subject land was a derivative title of TCT No. 722 and thus must be cancelled. Petitioner filed a Motion to Exclude with the RTC, arguing his title was not derived from TCT No. 722. The RTC denied his motion and subsequent motion for reconsideration, finding he failed to produce sufficient evidence to overthrow the TWC’s findings. Petitioner then filed a Rule 65 petition for certiorari with the Court of Appeals, which was denied. The CA affirmed the RTC Orders, leading to the present Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals committed reversible errors in affirming the RTC Orders that cancelled petitioner’s TCT No. T-51621, specifically by failing to consider that: (i) petitioner was never a party to the original reversion cases, so a separate reversion case should have been filed against him; (ii) the Decision in the Ayala y Cia and Zobel cases does not bind him; (iii) the cancellation was done without an actual ground survey; and (iv) petitioner is an innocent purchaser for value of alienable and disposable land from the DAR.

RULING

The Supreme Court DENIED the Petition and AFFIRMED the CA Decision and Resolution. The Court held that the CA correctly found no grave abuse of discretion by the RTC.
1. On the lack of party status and binding effect of the judgment: The CA correctly ruled that a reversion suit is an action in rem, binding upon the whole world, including the petitioner. The cancellation of derivative titles is a necessary consequence of the final and executory judgment in the reversion cases. The Supreme Court’s prior resolutions had already definitively settled the nullity of all subdivision titles derived from TCT No. 722 over the excess areas. Petitioner’s title, having been traced as a derivative of the void title, is subject to cancellation without the need for a separate suit against him personally.
2. On the absence of an actual ground survey: The Court noted that the relocation survey ordered was merely a tool to ensure accurate execution of the final judgment, not a prerequisite. The Supreme Court had previously stated in its October 6, 2008 Resolution that the fallo of the 1962 CFI Decision was “sufficiently complete for purposes of execution” and that the survey was to prevent error, not to reopen litigated issues.
3. On being an innocent purchaser for value: The Court affirmed that one who purchases from the government a lot that is part of the public domain acquires no better title than the government itself. The DAR’s error in selling land that was already declared part of the public domain and reverted to the State cannot prejudice the government. Registration under the Torrens system does not vest ownership if the land is not capable of private appropriation. Since the mother title (TCT No. 722) was void with respect to the excess areas, all derivative titles, including petitioner’s, are likewise void. The principle of innocent purchaser for value cannot apply where the land is inalienable public land.
The Court concluded that the matters raised had been thoroughly passed upon by the CA, and no reversible error was committed. The denial of the petition was final, as the issues were definitively settled in the earlier reversion cases.