G.R. No. 237663, October 06, 2020
Republic of the Philippines, Petitioner, vs. Heirs of Ma. Teresita A. Bernabe and Cooperative Rural Bank of Bulacan, Respondents.

FACTS

The Republic, through the Office of the Solicitor General (OSG), filed a Complaint for Cancellation of Title and Reversion concerning a parcel of land within the Clark Air Force Base, a former U.S. military reservation. The Republic alleged the land, originally part of the inalienable public domain, was fraudulently registered in 1968 under the name of Francisco Garcia, whose title was subsequently transferred to Ma. Teresita Bernabe. During the pendency of the suit, the Heirs of Bernabe mortgaged the property to respondent Cooperative Rural Bank of Bulacan (CRBB). The Republic then filed a Second Amended Complaint impleading CRBB, which was verified by the President of the Bases Conversion and Development Authority (BCDA).
CRBB filed a Motion to Dismiss, arguing the Republic was not the proper party to sue for reversion, as that power resides with the Director of Lands. It further contended the verification by the BCDA official was defective for lack of board authorization and that, as a government-owned or controlled corporation (GOCC), the BCDA could not invoke the state’s immunity from prescription. The Regional Trial Court granted the motion to dismiss, a ruling affirmed by the Court of Appeals.

ISSUE

The core issue is whether the Republic, through the OSG, is the proper party to institute an action for reversion of land alleged to be part of the inalienable public domain.

RULING

The Supreme Court GRANTED the petition, REVERSED the assailed CA Decision, and REINSTATED the Republic’s Second Amended Complaint. The Court held that the Republic is always the proper party to bring a reversion suit. The action is fundamentally an exercise of the state’s sovereign power and its right of dominium over lands of the public domain. While the Public Land Act designates the Director of Lands to administer and dispose of alienable public lands, an action to revert property wrongfully registered is inherently a governmental function aimed at correcting a nullity in the title. The OSG, as the Republic’s statutory counsel, is precisely mandated to represent the government in such litigation. The Court clarified that the BCDA’s involvement was merely to provide factual support as the agency managing the base area, but the real party-in-interest remains the Republic itself. Consequently, the procedural objections regarding the BCDA official’s verification and the defense of prescription against the state were rendered moot and baseless. The case was remanded to the trial court for further proceedings on the merits of the reversion claim.