G.R. No. L-3330 April 20, 1951
PHILIPPINE MINES SYNDICATE, plaintiff-appellant, vs. GUIREY, THE SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, THE DIRECTOR OF LANDS, THE REGISTER OF DEEDS OF BAGUIO AND BENGUET, and ATOK-BIG WEDGE MINING COMPANY, defendants-appellees.

FACTS

The plaintiff, Philippine Mines Syndicate, a mining corporation, filed a complaint in the Court of First Instance of Manila against the defendants. It alleged that defendant Guirey applied for a free patent over two parcels of land in Itogon, Mountain Province. The plaintiff opposed the application regarding Lot No. 1, claiming it was within its mining claim called “Charing,” ceded to it by Narba Mining Association. The Secretary of Agriculture and Commerce, after hearing, denied Guirey’s application for Lot No. 1 on April 29, 1939, declaring it more suitable for mining than agricultural purposes. Subsequently, Guirey, Atok Mining Company, and Big Wedge Mining Company filed a mandamus petition in the Court of First Instance of Baguio against the Secretary, the Director of Lands, and the plaintiff (Civil Case No. 758). On February 5, 1941, judgment was rendered in favor of the petitioners, and the defendants appealed to the Court of Appeals. The records of this case were destroyed in February 1945 during the liberation of Manila, and no reconstitution was requested. On May 31, 1948, upon Guirey’s petition, the Secretary of Agriculture and Natural Resources, upon recommendation of the Director of Lands, issued Free Patent Certificate V-168 (including Lot No. 1) in favor of Guirey, contrary to the 1939 order. This certificate was registered, and Original Certificate of Title No. P-2, Benguet, was issued. Atok-Big Wedge Mining Company is now the lessee of Lot No. 1. The plaintiff sought declarations that: the 1939 decision was final; the 1941 Baguio court decision was null; the free patent and the derivative certificate of title were null and void; and for costs. The Secretary of Agriculture and the Director of Lands moved to dismiss the complaint for lack of jurisdiction, which the trial court granted. The plaintiff appealed, contending the action was personal, concerning the officials’ acts in issuing the patent, and venue was properly in Manila under the general rule.

ISSUE

Whether the Court of First Instance of Manila had jurisdiction over the action, which sought to nullify a free patent and a certificate of title over a specific parcel of land located in Benguet.

RULING

The Supreme Court affirmed the order dismissing the complaint. The action is a real action affecting title to real property under Section 3, Rule 5 of the Rules of Court, which mandates that such actions “shall be commenced and tried in the province where the property or any part thereof lies.” The plaintiff’s own allegations—that Lot No. 1 is within its mining claim and is more suitable for mining—are material facts that could determine the patent’s nullity. Conversely, the defendants would need to prove facts such as Guirey’s occupation since July 4, 1907, to justify the patent issuance. These facts can be more easily and less expensively proved in Benguet, where the land is situated. Requiring Guirey to appear in Manila would deprive him of his right to defend himself conveniently. The free patent is intimately and inherently related to the land itself. Therefore, the plaintiff’s contention that Lot No. 1 was not the object of the suit is untenable. The cardinal reason for the venue rule is to facilitate the settlement of disputes.