G.R. No. 247490 . March 02, 2022
MA. LUISA ANNABELLE A. TORRES, RODOLFO A. TORRES, JR., AND RICHARD A. TORRES, PETITIONERS, VS. REPUBLIC OF THE PHILIPPINES, AND REGISTER OF DEEDS OF DAVAO CITY, RESPONDENTS.

FACTS

On April 5, 1991, the Republic of the Philippines filed a Complaint for Cancellation of Titles against Spouses Leonora and Florencio Gaspar before the Regional Trial Court (RTC), Branch 8, Davao City, seeking the cancellation of their free patents and original certificates of title (OCTs) and the reversion of the covered lots to the government. In a Decision dated April 20, 1999, the RTC granted the complaint, ordered the cancellation of the patents and titles, and decreed the reversion of the lots. This decision was affirmed by the Court of Appeals (CA) and subsequently became final and executory after the Supreme Court denied Leonora Gaspar’s petition.
During the execution stage, the Republic filed a motion for the cancellation of all derivative titles emanating from the cancelled OCTs of the Spouses Gaspar. On June 30, 2015, the RTC issued an Order granting the motion and specifically ordering the cancellation of several Transfer Certificates of Title (TCTs), including TCT Nos. T-304045, T-304046, T-304047, T-304048, and T-304050, which were derivative titles of OCT No. P-10221 and were registered in the names of petitioners Ma. Luisa Annabelle A. Torres, Rodolfo A. Torres, Jr., and Richard A. Torres.
Petitioners, who were not parties to the original reversion case (Civil Case No. 20,665-91), filed a petition for annulment of judgment under Rule 47 of the Rules of Court before the CA, assailing the RTC’s June 30, 2015 Order. They alleged lack of jurisdiction and denial of due process, claiming they were buyers in good faith and were not parties to the proceedings. The CA dismissed the petition, ruling that the assailed Order was issued in the exercise of the RTC’s residual authority to enforce its final and executory decision and was not a final judgment, order, or resolution subject to annulment under Rule 47. The CA cited its prior resolution in a similar case, Hsi Pin Liu, et al. v. Republic of the Philippines, which involved the same RTC Order. Petitioners’ motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for annulment of judgment, which assailed the RTC Order dated June 30, 2015 that cancelled petitioners’ derivative titles.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the CA’s resolutions.
The Supreme Court held that a petition for annulment of judgment under Rule 47 is a remedy available only against final and executory judgments, final orders, or resolutions. The RTC Order dated June 30, 2015 was not a judgment or final order on the merits of the reversion case but was merely an order issued during the execution stage to enforce the RTC’s final and executory Decision dated April 20, 1999. Such an order of execution, issued pursuant to the court’s residual authority under Section 6, Rule 135 of the Rules of Court to carry its jurisdiction into effect, is not the proper subject of a petition for annulment of judgment.
The Court further ruled that the cancellation of petitioners’ derivative titles was a necessary consequence of the final judgment ordering the cancellation of the mother titles (the Gaspars’ OCTs) from which they were derived. Since the mother titles were void ab initio due to fraud, all titles emanating from them were likewise void. Petitioners, as successors-in-interest, were bound by the judgment against their predecessors. Their claim of being buyers in good faith was irrelevant in a reversion case, as the State’s action for reversion impresses upon the land the character of public dominion, and such action is not subject to prescription. The Court also noted that the CA correctly applied the doctrine of stare decisis, as the issue had already been resolved in the prior similar case of Hsi Pin Liu, et al. v. Republic of the Philippines.