GR L 34199; (May, 1983) (Digest)
G.R. No. L-34199 May 30, 1983
Republic of the Philippines, petitioner, vs. Hon. Santiago O. Tañada, as Judge of the Court of First Instance of Cebu, Branch V, and Spouses Jacinto K. Rafanan and Vicenta L. Rafanan, respondents.
FACTS
The Republic of the Philippines, through the Board of Liquidators, sold two parcels of land to Delfin N. Lopez in 1959. These lands were former enemy-owned properties vested in the Philippine government under the Philippine Property Act of 1946. Lopez subsequently sold the lands to Mariano Ho, Sr. in December 1959, who then sold them to the respondent spouses, Jacinto and Vicenta Rafanan, in 1962. The Republic filed a complaint for reversion, alleging the original sale to Lopez was null and void for lack of the required presidential approval as mandated by Republic Act No. 477. The parties submitted a stipulation of facts, which was silent on the presence or absence of such presidential approval, and the trial court rendered a decision dismissing the complaint.
ISSUE
The core issue is whether the absence of presidential approval for the initial sale of government property under R.A. No. 477 renders the entire chain of subsequent transfers void, thereby justifying reversion of the property to the State.
RULING
The Supreme Court granted the petition and ordered the reversion of the lands to the Republic. The legal logic is anchored on the mandatory and jurisdictional nature of the presidential approval requirement under Section 79(b) of the Revised Administrative Code and Section 1 of R.A. No. 477. The Court held that the authority of the Board of Liquidators to alienate government property was not plenary but was contingent upon such presidential approval. Consequently, the deed of sale executed without this approval was void ab initio, conferring no rights upon the vendee, Lopez. Since Lopez acquired no valid title, he could not transmit any to Ho, and Ho, in turn, could not convey any to the Rafanan spouses. The stipulation of facts, while silent on approval, did not preclude the petitioner from proving its absence, as the burden to establish the validity of the sale (including the requisite approval) rested on the party asserting it. The Court distinguished the doctrine of pari delicto, noting it does not apply when the agreement is void for lack of statutory authority, and emphasized that the State, as the original owner, may institute reversion proceedings to recover property alienated in violation of law.