LTD Case Digests

REPUBLIC OF THE PHILIPPINES, PHILIPPINES, v. MARJENS INVESTMENT CORPORATION, G.R. No. 156205, Noveme Noveme! ! 12, 12, 201" F#$%&' On December 22, 1998, or almost 46 years after the issuance of OCT No. 0669, !e"ublic, re"resente# by the !e$ion %& !e$ional '(ecuti)e Director of the D'N!, *le# a "etition before the Court Co urt of +" +""e "eal als s fo forr ann annulm ulment ent of u# u#$m $men ent, t, ca cance ncella llati tion on of tit title le,, an an# # re re)er )ersio sion n a$ a$ain ainst st res"on#ents, the !e$ister of Dee#s for the -ro)ince of atan$as, an# the !e$ional Trial Court of  /i"a City. -etitioner alle$es that res"on#ents a""ear as re$istere# oners of a lan# i#enti*e# as /ot 1 -cs 94, hich is a "ortion of /ots 1 an# 2, "lan -su11440 /!C !ecor# No. N44, co)ere# by TCT No. T1892.  The O3 alle$es that u"on )eri*cation, it as ascertaine# that the lan# co)ere# by TCT No. T 1892 18 92 is ith ithin in the uncl unclassi assi*e# *e# "ublic for forest est "er /an# Cla Classi* ssi*cati cation on Con Contr trol ol 5a" No No.. 10 10,, therefore, cannot be subect of #is"osition or re$istration an# the re$istration "rocee#in$s, the  u#$ment in the subect case, the OCT No. O669 issue# "ursuant thereto, an# all subseuent titles are null an# )oi#. The lan# co)ere# by TCT No. T1892, not ha)in$ been le$ally re$istere#, remains an# forms "art of the "ublic #omain of the 3tate. %n their comment, res"on#ents #eny the O37s alle$ations. They claim that their titles, their "re#ec "r e#ecess essors7 ors7 titles, titles, an# their moth mother er titl title e ar are e issu issue# e# in acco accor# r#ance ance ith la, an# that the "ro"erty as re$istere# an# brou$ht un#er the Torrens system. !es"on#ents conten# that the subect "ro"erty as alrea#y "ri)ate "ro"erty e)en before the 3"anish Cron ce#e# so)erei$nty o)er the -hili""ine %slan#s to the nite# 3tates of +merica.  The Court of +""eals #ismisse# #ismis se# the case an# a""lie# a" "lie# the case of Cariho v. Insular Government of  the Philippin Philippine e %slan#s, hich reco$nie# reco$nie# "ri)ate onershi" of lan#s alrea#y "ossesse# or hel# by in#i)i#uals un#er claim of onershi" as far bac: as testimony or memory $oes an# therefore ne)er to ha)e been "ublic lan# that 3"ain coul# beueath to the nite# 3tates of +merica. ncon)ince#, the O3 *le# this "etition for re)ie on certiorari certiorari before  before the Court. sub ect "ro"erty is a "ri)ate "ro"erty. "ro"erty. I&&(e' ;"rescri"tion is mentione# a$ain in the royal ce#ula of October 1, 1?4, cite# in  -hili""ine, 46@ 7>Ahere such "ossessors shall not be able to "ro#uce title #ee#s, it shall be suBcient if they shall sho that ancient "ossession, as a )ali# title by "rescri"tion.7 %t may be that this means "ossession from before 1?00@ but, at all e)ents, the "rinci"le is a#mitte#. +s "rescri"tion, e)en a$ainst a$a inst Cron Cron lan# lan#s, s, as reco$ni reco$nie# e# by the las of 3"ain e see no suB suBcien cientt re reaso ason n for hesitatin$ to a#mit that it as reco$nie# in the -hili""ines in re$ar# to lan#s o)er hich 3"ain ha# only a "a"er so)erei$nty s o)erei$nty.= .= +s for res"on#ents, it is un#is"ute# that the subect "ro"erty traces its title to the "ro"erty ori$inally one# by !ita &#a. #e %lustre since 1890. rom her it "asse# on to se)eral han#s until it as transferre# to ammon . uc:, ho successfully re$istere# it in his name. rom 1890, res"on#ents7 "re#ecessors in interest ha# been in "eaceful, o"en, continuous, e(clusi)e, a#)erse, an# an # no noto torio rious us "o "osse ssessi ssion on in the co conce nce"t "t of an o one nerr of th the e sub sube ect ct "r "ro"e o"erty rty. oll ollo oin$ in$ the Cariño Cariño rulin$,  rulin$, the subect "ro"erty ha# been a "ri)ate lan# an# e(clu#e# from the "ublic #omain since 1890 "rior to the si$nin$ of the Treaty of -aris on December 10, 1898. Therefore, it

is not "art of the "ublic #omain that "asse# on from 3"ain to the nite# 3tates of +merica. or the same reason, it is also not "art of the unclassi*e# "ublic forest as "etitioner claims. %nRepublic v. Court of Appeals and Cosalan, the Court hel# that = 7hile the o)ernment has the ri$ht to classify "ortions of "ublic lan#, the "rimary ri$ht of a "ri)ate in#i)i#ual ho "ossesse# an# culti)ate# the lan# in $oo# faith much "rior to such classi*cation must be reco$nie# an# shoul# not be "reu#ice# E be consi#ere# forestry lan#, unless "ri)ate interests ha)e inter)ene# before such reser)ation is ma#e7= R(*+-' ;'!'O!', "remises consi#ere#, the Court of +""eals Decision is +%!5'D.

ANDY ANG, v. SEVERINO PACUNIO, G.R. No. 208928, July 08, 2015 Fac!" Respondents filed a complaint for Declaration for nullity of Sale, Reconveyance and damages before the RTC involving the subject land originally owned by Udiaan. Respondents alleged that they are grandchildren and successorininterest of Udiaan. !owever, an imposter falsely representing herself as Udiaan sold the subject land to petitioner. "etitioner entered the subject land and used the same in his livestoc# business. Respondents then informed petitioner that he did not validly ac$uire the subject land, and thereafter, demanded its return, but to no avail. !ence, they filed the aforesaid complaint, contending the Udiaan cannot sold the subject considering that she was already dead for more than %& years when the sale occurred. "etitioner denied respondents' allegations and countered that( ) a* at first, he bought the subject land from a person representing herself as Udiaan who showed a community ta+ certificate as proof of identity, has in her possession CT -o. T/0, #new the location of the subject land, and was not afraid to face the notary public when they e+ecuted the 1uestioned Deed of 2bsolute Sale3 ) b* he was initially prevented from entering the subject land since it was being occupied by the !eirs of 2lfredo 4accion3 ) c * in order to buy peace, he had to 5buy5 the subject land anew from the !eirs of 4accion3 ) d * he was a buyer in good faith, for value, and was without any #nowledge or participation in the alleged defects of the title thereof3 and ) e* respondents were never in possession of the subject land and they never paid real property ta+es over the same. Ultimately, petitioner claimed that he was duped and swindled into buying the subject land twice.

!TC rule# in fa)our of the "etitioner. C+ mo#i*e# !TCFs #ecision as follosG )a* ,/&% s$. m. to petitioner3 )b* 6,07 s$. m. to the !eirs of 4accion3 and )c* the remainder of the subject land to Udiaan's children. "etitioner 8R but was denied, hence, this petition.

I!!u#" 9:- the respondents are not real parties in interest. Discussion( The rule on real parties in interest has two )%* re$uirements, namely( ) a* to institute an action, the plaintiff must be the real party in interest3 and ) b* the action must be prosecuted in the name of the real party in interest. ;nterest within the meaning of the Rules of Court means material interest or an interest in issue to be affected by the decree or judgment of the case, as distinguished from mere curiosity about the $uestion involved. ne having no material interest cannot invo#e the jurisdiction of the court as the plaintiff  in an action. 9hen the plaintiff is not the real party in interest, the case is dismissible on the ground of lac# of cause of action. ;n the instant case, respondents claim to be the successorsininterest of the subject land just because they are Udiaan's grandchildren. Under the law, however, respondents will only be deemed to have a material

interest over the subject land and the rest of Udiaan's estate for that matter if the right of representation &

=

provided under 2rticle 0or such right to be available to respondents, they would have to show first that their mother( )a* predeceased Udiaan3 ) b* is incapacitated to inherit3 or ) c * was disinherited, if Udiaan died testate. !owever, as correctly pointed out by the C2, nothing in the records would show that the right of representation is available to respondents. !ence, the RTC and the C2 correctly found that respondents are not real parties in interest to the instant case. ;t is wellsettled that factual findings of the RTC, when affirmed by the C2, are entitled to great weight and respect by the Court and are deemed final and conclusive when supported by the evidence on record, as in this case.

Rul$%&" 9!?R?>R?, the petition is 4R2-T?D.

SPOUSES )OMINA)OR MARCOS #+ GLORIA MARCOS, v. HEIRS OF ISI)RO BANGI, G.R. No. 1/5"5, O$%oe! 15, 201" F#$%&' On Hune 26, 1998, the heirs of %si#roI an# eno)e)a, *le# ith the !TC a com"laint for annulment of #ocuments, cancellation of transfer certi*cates of titles, restoration of ori$inal certi*cate of title an# reco)ery of onershi" "lus #ama$es a$ainst s"ouses Domina#or an# loria. /i:eise im"lea#e# in the sai# com"laint are s"ouses Hose an# -acita, Ceasaria , an# s"ouses 'milio an# Jenai#a. %n their com"laint, the res"on#ents a)erre# that their "arents, %si#ro an# eno)e)a, bou$ht the onethir# "ortion of subect "ro"erty from 'usebio, as e)i#ence# by a Dee# of +bsolute 3ale e(ecute# by the latter, hich as subseuently re$istere# in the name of +li"io, 'usebioFs father. +fter the sale, the res"on#ents claime# that %si#ro an# eno)e)a too: "ossession of the subect "ro"erty until they "asse# aay. The res"on#ents then too: "ossession of the same. urther, the res"on#ents alle$e# that sometime in 1998, they learne# that the title to the subect "ro"erty, inclu#in$ the "ortion sol# to %si#ro an# eno)e)a, as transferre# to herein "etitioner Domina#or, -rimo, CeasariaFs husban#, Hose, an# 'milio throu$h a Dee# of +bsolute 3ale #ate# +u$ust 10, 199, su""ose#ly e(ecute# by +li"io ith the consent of his ife !amona. The res"on#ents claime# that the sai# #ee# of absolute sale is a for$ery since +li"io #ie# in 1918 hile !amona "asse# aay on Hune 1, 19?. -etitioners, to$ether ith the s"ouses Hose an# -acita, Ceasaria an# the s"ouses 'milio an# Jenai#a, #enie# the alle$ations of the res"on#ents, claimin$ that they are the oners of the subect "ro"erty, inclu#in$ the onethir# "ortion thereof alle$e#ly sol# by 'usebio to the res"on#entsF "arents %si#ro an# eno)e)a. !TC rule# in fa)our of the res"on#ent. C+ #enie# the 5!. ence, this "etition. I&&(e' ;