G.R. No. L-45202 September 11, 1980
Republic of the Philippines, petitioner, vs. The Honorable Court of Appeals, Landolino Alpuerto, Paz Alpuerto, Norma Alpuerto, Francisca Alpuerto, in their capacity as heirs of Perpetuo Alpuerto, Henry O. Antonio Angeles, Aurea Angeles, Industrial Marketing & Investment Corp., Landolino Alpuerto, Lucila Unlayao, Artemio Calusin, Luciano Potestades, Elpidio Banagan, Luz Oliveros, Dionisio Llamas, Alicia Caparros, Corazon Alpuente, Emilio Caliwara, Andres Lariedo, Land Registration Commissioner and Register of Deeds of Quezon, respondents.

FACTS

This case involves Lot No. 7718 in Mauban, Quezon. Perpetuo Alpuerto successfully moved to reopen the cadastral case for this lot. The Court of First Instance adjudicated the land to him in 1966, leading to the issuance of Original Certificate of Title No. 0-13541. Portions of the lot were subsequently sold to various private respondents. The Provincial Fiscal and later the Solicitor General, representing the Director of Lands, filed motions for reconsideration and a new trial, arguing the reopening was improper and the decision was obtained through fraud. These motions were denied.
Subsequently, the Republic filed a complaint for annulment and reversion, alleging the land was inalienable public forest land, thus the registration court lacked jurisdiction. The lower court dismissed the complaint, a decision affirmed by the Court of Appeals. The appellate court held the action was barred by prior judgment and that the State’s claim regarding the land’s inalienable character was raised too late. The Republic elevated the case to the Supreme Court via certiorari.

ISSUE

Whether an action for reversion and cancellation of title, based on the allegation that the land is inalienable forest land, is barred by the prior judgment of the registration court.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals. The legal logic is anchored on the fundamental principle of jurisdiction. The Court ruled that if the subject land is indeed inalienable public forest land, it is outside the commerce of man and cannot be registered under the Torrens system. The jurisdiction of the registration court is limited to alienable and disposable lands of the public domain. Consequently, a judgment rendered by a court without jurisdiction over the subject matter is void and produces no legal effect.
Since a void judgment is a legal nullity, the doctrine of res judicata cannot apply. For res judicata to bar a subsequent action, the prior judgment must have been rendered by a court with proper jurisdiction over the subject matter. This essential requisite was absent if the land was forest land. Therefore, the State’s action for reversion, which is an assertion of its imprescriptible ownership over inalienable land, cannot be barred. The Court further held that the doctrine of estoppel cannot be invoked against the State in such cases, and prescription does not run against the sovereign. The case was remanded to the trial court for further proceedings to determine the true character of the land.