GR L 21543; (April, 1979) (Digest)
G.R. No. L-21543 April 30, 1979
MARCOS ESTANISLAO, ET AL., plaintiffs-appellants, vs. THE DEPARTMENT OF AGRICULTURE AND NATURAL RESOURCES AND THE PEOPLE’S HOMESITE AND HOUSING CORPORATION, defendants-appellees.
FACTS
The plaintiffs-appellants, the Estanislaos and Marcelino Tiburcio, filed a suit seeking the nullification of Original Certificate of Title (OCT) No. 735 and all subsequent transfer certificates of title derived from it. Their core allegation was that these titles were issued not in accordance with a 1913 decision in G.L.R.O. Record No. 7681, which they claimed should have confined the titled area to only 5,750,000 square meters. They argued that the titles in question, which covered the land known as Finca No. 2088, were therefore void for exceeding this purported limitation. The defendants-appellees, the Department of Agriculture and Natural Resources (DANR) and the People’s Homesite and Housing Corporation (PHHC), moved for the dismissal of the complaint. The lower court granted the motion, prompting the plaintiffs to appeal the order of dismissal to the Supreme Court.
ISSUE
The principal issue is whether the complaint states a cause of action, given the appellants’ direct attack on the validity of OCT No. 735. A subsidiary procedural issue is whether the lower court erred in not declaring the defendant DANR in default.
RULING
The Supreme Court affirmed the order of dismissal, ruling the appeal to be utterly without merit. The Court held that the appellants’ cause of action was fatally infirm from the outset because it sought to relitigate the validity of OCT No. 735, a matter already settled with finality in a long line of jurisprudence. The Court specifically cited the exhaustive ruling in Benin v. Tuason and the decision in People’s Homesite and Housing Corporation v. Mencias, which themselves referenced earlier cases like Tiburcio v. PHHC and Galvez v. Tuason. These precedents had repeatedly and conclusively upheld the validity of OCT No. 735 against various challenges. The Court emphasized that to entertain the appellants’ claim would be to overturn numerous binding decisions, an act that would be “unsound in theory and pernicious in practice” due to the wholesale disturbance of established property rights it would cause.
The Court further noted that the futility of the appeal was underscored by its own prior decision in Estanislao v. Government Service Insurance System, which involved some of the same appellants and the same counsel, and which had already dismissed an identical attack on OCT No. 735 as devoid of merit. On the procedural issue, the Court found no error in not declaring DANR in default. It noted that the state agency may not be sued without its consent, and even assuming it was a proper party, procedural rules are applied restrictively when the government is involved. Moreover, any default would be inconsequential since DANR, like PHHC, derived its rights from an innocent purchaser for value, a status vigorously protected by the Court. The appeal was thus dismissed for being a hopeless quest against settled law.