G.R. No. 50464 ; January 29, 1990
SUNBEAM CONVENIENCE FOODS INC., CORAL BEACH DEVELOPMENT CORP., and the REGISTER OF DEEDS OF BATAAN, petitioners, vs. HON. COURT OF APPEALS and THE REPUBLIC OF THE PHILIPPINES, respondents.

FACTS

The Republic of the Philippines, through the Solicitor General, filed an action for reversion before the Court of First Instance of Bataan. The complaint alleged that two parcels of land in Mariveles, Bataan, for which a Sales Patent was issued to Sunbeam Convenience Foods Inc. (Sunbeam) and titles were subsequently transferred to Coral Beach Development Corp. (Coral Beach), were inalienable forest lands. Sunbeam and Coral Beach moved to dismiss the complaint on grounds including failure to exhaust administrative remedies, the indefeasibility of their titles, and the alleged defect that the action was initiated by the Solicitor General instead of the Director of Lands. The trial court granted the motion to dismiss, ruling that jurisdiction over the land disposition lay with the Bureau of Lands.
The Solicitor General initially filed a notice of appeal but later opted to file a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion by the trial court in dismissing the complaint. The Court of Appeals granted the petition, set aside the order of dismissal, and directed the trial court to proceed with the case. Sunbeam and Coral Beach then elevated the matter to the Supreme Court via a petition for review.

ISSUE

Whether the Court of Appeals erred in granting the petition for certiorari and setting aside the trial court’s order dismissing the Republic’s complaint for reversion.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the trial court committed grave abuse of discretion in dismissing the complaint based on a motion to dismiss. In ruling on such a motion, the material allegations in the complaint are deemed hypothetically admitted. The Republic’s complaint squarely alleged that the subject lands were forest lands and therefore inalienable. This central factual allegation was not specifically denied by the petitioners in their motion. The legal consequence is critical: if the lands are indeed forest lands, they are part of the public domain under the Regalian doctrine and cannot be the subject of a sales patent or private title. A positive act of declassification by the government is required before such lands can be declared alienable. The trial court’s dismissal effectively precluded a trial on this pivotal factual issue. The Court further found no merit in the procedural objections. The action for reversion, which seeks to revert land to the public domain, is inherently a judicial function properly initiated by the Solicitor General on behalf of the Republic. Exhaustion of administrative remedies is not required, and the indefeasibility of a title does not apply when the patent and title are void ab initio, as when issued over inalienable land. The Court of Appeals correctly exercised its certiorari jurisdiction to correct this grave abuse, and no reversible error was committed.