Professional Documents
Culture Documents
LTD Batch 3
LTD Batch 3
The court cited Mejia de Lucas vs. Gamponia, wherein the land in question came into
the possession of the defendant-appellant Gamponia after a series of transfers from 32. HALILI VS CIR
Domingo Mejia, the original owner and plaintiff-appellee's (Mejia de Lucas') GR L-24864 MAY 30, 1996
predecessor-in-interest to three other persons and their successors-in-interest, whose
rights and obligation would have been affected by a contrary decision. In the Mejia de DOCTRINE:
Lucas case, The court holds that while defendant may not be considered as having
Section 48 of PD 1529 states that such a certificate shall not be subject to collateral Hence present case: the union filed a Petition/Motion with Prayer for Clarification, also
attack. And it cannot be altered, modified, or cancelled except in a direct proceeding in seeking the recovery of the subject real property.
accordance with law for that purpose.
ISSUE/S: Can the Union be granted the property? NO. The petition is a collateral attack
The issue on the validity of title, i.e., whether or not it was fraudulently issued, can only on the title. [Motion to recover = objective is to nullify MMPCI’s title]
be raised in an action expressly instituted for that purpose.
HELD:
FACTS: ü The NLRC’s jurisdiction[1] does not include recognizing cases involving
(1) For unpaid overtime pay, 897 employees of Halili Transit filed several actions reconveyance making the outright dismissal proper.
against Fortunato Halili with the Court of Industrial Relations in 1958. After ü The fact that the subject real property was registered under the Torrens System
Halili’s death, the cases were settled amicably. of registration in the name of respondent MMPCI under Transfer Certificate
(2) The amicable settlement covered the transfer of the title to a 33,952 sqm of Title No. 301151 by the Register of Deeds of Quezon City on June 14, 1983,
tract of land in San Bartolome, Caloocan in addition to a cash payment of makes the instant petition all the more dismissible, considering that the best
P25,000 to the employees. proof of ownership of a piece of land is the Certificate of Title.
(3) The administratrix of Halili’s estate then later executed a deed of conveyance o Section 48 of PD 1529 states that such a certificate shall not be
of real property, transferring the title to the subject tract of land to the Halili subject to collateral attack. And it cannot be altered, modified, or
Bus and Conductor’s Union, to be held in trust by the said union for the cancelled except in a direct proceeding in accordance with law for
employees. that purpose.
(4) The parcel of land was then registered without any encumbrance under a ü A certificate of title accumulates in one document a precise and correct
new certificate of title. statement of the exact status of the fee held by its owner.
(5) Atty. Benjamin Pineda of the union then filed a motion with the Ministry of ü The certificate, in the absence of fraud, is the evidence of title and shows
Labor and Employment (MOLE) requesting that authority be given to sell the exactly the real interest of its owner. With very few exceptions, this title once
land, as well as the Supreme Court, which was granted by both. registered should not thereafter be impugned, altered, changed, modified,
(6) Relying on the authority, Atty. Pineda then filed a motion for authority to sell enlarged, or diminished, except in some direct proceeding permitted by law.
the land to the Manila Memorial Park Cemetery, Inc., which was also granted ü If the rule were otherwise, all security in registered titles would be lost.
by the MOLE through the decision of Labor Arbiter Valenzuela.
(7) After the sale’s consummation, a new certificate of title was issued to In the case at bar, the Union seeks from MMPCI the recovery of the subject property. It
MMPCI. is evident that the objective of such claim is to nullify MMPCI’s title to the property in
(8) The Supreme Court, however, later set aside both orders granting the motion question, which thereby challenges the judgment pursuant to which the title was
to sell to MMPCI after the same were challenged by the Solicitor General (for decreed, an apparent a collateral attack, which is not permitted under the principle of
being issued without due process). indefeasibility of a Torrens Title
(9) On the basis of the Resolution setting aside the authorizations by the LA, the ü The issue on the validity of title, i.e., whether or not it was fraudulently issued,
Union then filed a complaint with the National Labor Relations Commission can only be raised in an action expressly instituted for that purpose. Hence,
(NLRC) to compel MMPCI to reconvey the property to the union. whether or not petitioners have the right to claim ownership of the land in
question is beyond the province of the instant proceeding.
NLRC: dismissed the complaint on the ground of lack of jurisdiction, (subject matter is a
proper subject of the regular courts).
Moreover, all portions the subject land (now the Holy Cross Memorial Park) have (c) Cases arising from the interpretation or implementation of collective
already been sold out to individual lot buyers, who are innocent purchasers for value, bargaining agreements and those arising from the interpretation or
and contain the interred remains of the lot owners and/or their relatives. enforcement of company personnel policies shall be disposed of by the
ü Where innocent third persons, relying on the correctness of the CT issued, Labor Arbiter by referring the same to the grievance machinery and
acquire over the property, the Court cannot disregard such rights and order voluntary arbitration as may be provided in said agreements. (As
the total cancellation of the certificate. amended by Section 9, Republic Act No. 6715, March 21, 1989)
Ownership of the lot had already been vested in the Union upon the sale of Halili’s 33 MADRID VS SPOUSES MARTINEZ
estate – they had every right to dispose of it. GR 150887 AUG 14, 2009
ü Cannot look into the validity of the property’s disposal because the judgments
have become final and executory. DOCTRINE:
Registration of land under the Torrens system, aside from perfecting the title and
Petition dismissed rendering it indefeasible after the lapse of the period allowed by law, also renders the
title immune from collateral attack
[1] Article 217. Jurisdiction of the Labor Arbiters and the Commission. FACTS:
(a) Except as otherwise provided under this Code, the Labor Arbiters shall have · Spouses Mapoy (respondents – plaintiffs) are the absolute owners of two
original and exclusive jurisdiction to hear and decide, within thirty (30) calendar parcels of land (with a combined area of 270 sqm.) in Sampaloc Manila under the
days after the submission of the case by the parties for decision without extension, TCT issued by the Registry of Deeds of Manila.
even in the absence of stenographic notes, the following cases involving all · April 4, 1988: Spouses Mapoy sought to recover the possession of the
workers, whether agricultural or non-agricultural: properties through an accion publiciana which was filed in the RTC of Manila
(1) Unfair labor practice cases; against the Mirandas and two other unnamed defendants who were later on
(2) Termination disputes; identified as Francisco Madrid and Edgardo Bernardo (petitioners).
(3) If accompanied with a claim for reinstatement, those cases that · Spouses Mapoy alleged that they acquired the properties from Spouses
workers may file involving wages, rates of pay, hours of work and Castelo under a Deed of Absolute Sale dated June 20, 1978.
other terms and conditions of employment; o According to them, they only tolerated the occupancy and
(4) Claims for actual, moral, exemplary and other forms of damages possession of the petitioners until it became illegal after they
arising from the employer-employee relations; refused to vacate the properties after repeated demands of
(5) Cases arising from any violation of Article 264 of this Code, Spouses Mapoy.
including questions involving the legality of strikes and lockouts; · The Mirandas countered that Gregorio Miranda owned the properties by
and virtue of an oral sale between him and the original owner, Antonio.
(6) Except claims for Employees Compensation, Social Security, o They claimed that Gregorio Miranda was a carpenter of
Medicare and maternity benefits, all other claims arising from Antonio, and that they had a verbal contract for him to stay,
employer-employee relations, including those of persons in develop, fix, and guard the properties – as a reward for his 20
domestic or household service, involving an amount exceeding five years of loyal servies, Antonio gave the properties to him.
thousand pesos (P5,000.00) regardless of whether accompanied o Bernardo asserted that he became a ward of Miranda in 1965
with a claim for reinstatement. when he was 10 years old and helped in the development of
(b) The Commission shall have exclusive appellate jurisdiction over all cases the properties and constructed a bodega and a house within
decided by Labor Arbiters. the properties.
o Madrid claimed that he stated occupying a portion of the action to obtain a different relief and as an incident of the present action, an attack is
properties in 1974, and constructed a house on this portion in made against the judgment granting the title. This manner of attack is to be
1989 with the permission of Bernardo (son of Miranda). distinguished from a direct attack against a judgment granting the title, through an
· Petitioners invoked Sec. 6 of the Urban Land Reform Law, granting legitimate action whose main objective is to annul, set aside, or enjoin the enforcement of such
tenants of 10/more, who have built their homes and continuously resided there judgment if not yet implemented, or to seek recovery if the property titled under the
for the past 10 years, the right of first refusal to purchase the lands within a judgment had been disposed of. To permit a collateral attack on respondents-plaintiffs
reasonable time and price. title is to water down the integrity and guaranteed legal indefeasibility of a Torrens title.
· RTC: upheld the rights of the respondents-plaintiffs right of possession as
registered owners of the property. The petitioners-defendants attack on the validity of respondents-plaintiffs
o No merit in the petitioners’ claims of ownership via oral sale title, by claiming that fraud attended its acquisition, is a collateral attack on the title. It
given the absence of any public instrument or note to support is an attack incidental to their quest to defend their possession of the properties in an
their claims. "accion publiciana," not in a direct action whose main objective is to impugn the validity
· CA: dismissed the appeal. The certificate of title in the name of the of the judgment granting the title. This is the attack that possession of a Torrens Title
respondents serves as evidence of an indefeasible and incontrovertible title to the specifically guards against; hence, we cannot entertain, much less accord credit to, the
properties. petitioners-defendants claim of fraud to impugn the validity of the respondents-
· Hence, this petition. plaintiffs title to their property.
1. That devoted to public use, such as roads, canals, rivers, torrents, ports and bridges The 1987 Constitution continues the State policy in the 1973 Constitution banning
constructed by the State, riverbanks, shores, roadsteads, and that of a similar private corporations from acquiring any kind of alienable land of the public domain.
character; Like the 1973 Constitution, the 1987 Constitution allows private corporations to hold
2. That belonging exclusively to the State which, without being of general public use, alienable lands of the public domain only through lease. As in the 1935 and 1973
is employed in some public service, or in the development of the national wealth, such Constitutions, the general law governing the lease to private corporations of reclaimed,
as walls, fortresses, and other works for the defense of the territory, and mines, until foreshore and marshy alienable lands of the public domain is still CA No. 141.
granted to private individuals.
Without the constitutional ban, individuals who already acquired the maximum area of
Property devoted to public use referred to property open for use by the public. In alienable lands of the public domain could easily set up corporations to acquire more
contrast, property devoted to public service referred to property used for some specific alienable public lands. An individual could own as many corporations as his means
public service and open only to those authorized to use the property.Property of public would allow him. An individual could even hide his ownership of a corporation by
dominion referred not only to property devoted to public use, but also to property not putting his nominees as stockholders of the corporation. The corporation is a
so used but employed to develop the national wealth. This class of property constituted convenient vehicle to circumvent the constitutional limitation on acquisition by
property of public dominion although employed for some economic or commercial individuals of alienable lands of the public domain.
activity to increase the national wealth.
PD No. 1085, coupled with President Aquino's actual issuance of a special patent
"Art. 341. Property of public dominion, when no longer devoted to public use or to covering the Freedom Islands, is equivalent to an official proclamation classifying the
the defense of the territory, shall become a part of the private property of the State." Freedom Islands as alienable or disposable lands of the public domain. Being neither
This provision, however, was not self-executing. The legislature, or the executive timber, mineral, nor national park lands, the reclaimed Freedom Islands necessarily fall
department pursuant to law, must declare the property no longer needed for public under the classification of agricultural lands of the public domain. Under the 1987
use or territorial defense before the government could lease or alienate the property to Constitution, agricultural lands of the public domain are the only natural resources that
private parties. the State may alienate to qualified private parties. All other natural resources, such as
the seas or bays, are "waters . . . owned by the State" forming part of the public
Act No. 2874 of the Philippine Legislature domain, and are inalienable pursuant to Section 2, Article XII of the 1987 Constitution.
In short, DENR is vested with the power to authorize the reclamation of areas under apply to government units and entities like PEA. The grant of legislative authority to sell
water, while PEA is vested with the power to undertake the physical reclamation of public lands in accordance with Section 60 of CA No. 141 does not automatically
areas under water whether directly or through private contractors. DENR is also convert alienable lands of the public domain into private or patrimonial lands. The
empowered to classify lands of the public domain into alienable or disposable lands alienable lands of the public domain must be transferred to qualified private parties, or
subject to the approval of the President. On the other hand, PEA is tasked to develop, to government entities not tasked to dispose of public lands, before these lands can
sell or lease the reclaimed alienable lands of the public domain. Clearly, the mere become private or patrimonial lands. Otherwise, the constitutional ban will become
physical act of reclamation by PEA of foreshore or submerged areas does not make the illusory if Congress can declare lands of the public domain as private or patrimonial
reclaimed lands alienable or disposable lands of the public domain, much less lands in the hands of a government agency tasked to dispose of public lands.
patrimonial lands of PEA. Likewise, the mere transfer by the National Government of
lands of the public domain to PEA does not make the lands alienable or disposable To allow vast areas of reclaimed lands of the public domain to be transferred to PEA as
lands of the public domain, much less patrimonial lands of PEA. private lands will sanction a gross violation of the constitutional ban on private
corporations from acquiring any kind of alienable land of the public domain. This
There is no express authority under either PD No. 1085 or EO No. 525 for PEA to sell its scheme can even be applied to alienable agricultural lands of the public domain since
reclaimed lands. PD No. 1085 merely transferred "ownership and administration" of PEA can "acquire . . . any and all kinds of lands." The 157.84 hectares of reclaimed
lands reclaimed from Manila Bay to PEA, while EO No. 525 declared that lands lands comprising the Freedom Islands, now covered by certificates of title in the name
reclaimed by PEA "shall belong to or be owned by PEA." PEA's charter, however, of PEA, are alienable lands of the public domain. PEA may lease these lands to private
expressly tasks PEA "to develop, improve, acquire, administer, deal in, subdivide, corporations but may not sell or transfer ownership of these lands to private
dispose, lease and sell any and all kinds of lands . . . owned, managed, controlled corporations.
and/or operated by the government." 87 (Emphasis supplied) There is, therefore,
legislative authority granted to PEA to sell its lands, whether patrimonial or alienable 7. Considering that the Amended JVA is null and void ab initio, there is no necessity to
lands of the public domain. PEA may sell to private parties its patrimonial properties in rule on this last issue. Besides, the Court is not the trier of facts, and this last issue
accordance with the PEA charter free from constitutional limitations. The constitutional involves a determination of factual matters.
ban on private corporations from acquiring alienable lands of the public domain does
not apply to the sale of PEA's patrimonial lands.
"Laches" has been defined as "such neglect or ommission to assert a right, taken in
conjunction with lapse of time and other circumstances causing prejudice to an adverse
party, as will operate as a bar in equity." It is a delay in the assertion of a right "which
works disadvantage to another" because of the "inequity founded on some change in 39. BINALAY VS MANALO
the condition or relations of the property or parties." GR 92161 MAR 18, 1991
DOCTRINE:
Laruan's sale of the subject lot to Lacamen could have been valid were it not for the FACTS:
sole fact that it lacked the approval of the Director of the Bureau of Non-Christian ISSUE/S:
Tribes. There was impressed upon its face full faith and credit after it was notarized by HELD:
the notary public. The non-approval was the only "drawback" of which the trial court
has found the respondents-appellants to "have taken advantage as their lever to
40. REPUBLIC VS CA
deprive [petitioners-appellants] of this land and that their motive is out and out greed."
GR 103882 NOV 25, 1998
As between Laruan and Lacamen, the sale was regular, not infected with any flaw.
DOCTRINE:
Laruan's delivery of his certificate of title to Lacamen just after the sale symbolizes
FACTS:
nothing more than a bared recognition and acceptance on his part that Lacamen is the
ISSUE/S:
new owner of the property. Thus, not any antagonistic show of ownership was ever
HELD:
exhibited by Laruan after that sale and until his death in May 1938.
45. REPUBLIC VS CA
GR 108998 AUG 24, 1994
DOCTRINE:
FACTS:
ISSUE/S:
HELD: