REPUBLIC OF THE PHILIPPINES, Petitioner, v. SPS. VIRGILIO and ANNA RAMIREZ LONTOK, RISING SUN MOTORS CORPORATION, and the REGISTER OF DEEDS OF LOS BANOS and SANTA CRUZ, LAGUNA
Famous statement from this jurisprudence:
Failure to state a cause of action refers to the insufficiency of the state a cause of action. Only the allegations in the complaint may properly be considered.
FACTS:
Anna R. Lontok (A. lontok) was granted Free Patent by the DENR on 30 May 1986 and issued OCT by Registry of Deeds.
On 11 November 1991, A. Lontok sold 1,623 sq. meter portion of the subject property to the Rising Sun Motors Corporation. TCT was issued by the ROD of the Province of Laguna to Rising Sun on 25 November 1991 and numbered as TCT No. T-1 29346.
It appears on record that OCT No. P-8554 had been totally cancelled by TCT No. T-129346 and TCTs Nos. 129354-55, but no other information exists as to the specificity of the two latter titles.
On 19 January 1994, the heirs of Sps. Bartolome filed a formal protest before the DENR against the issuance of the free patent in A. Lontok’s name.
ISSUE:
I. Whether or not the CA committed a reversible error in finding that the Republic failed to establish its cause of action
II. Whether or not the State has Cause of Action in this case
III. Whether or not the subject lot is a public domain
IV. Whether or not the Director of Lands has Jurisdiction over the property.
V. Whether or not the dismissal of the subject complaint to be improper
RULING
I. No. CA did not commit a reversible error.
The Supreme Court agrees with the CA in faulting the Republic for its failure to state a cause of action in relation to its prayer for reversion.
Failure to state a cause of action refers to the insufficiency of the state a cause of action.
Only the allegations in the complaint may properly be considered.
Failure to make a sufficient allegation of a cause of action in the complaint “warrants its dismissal.”
II. No, the state has no cause action in this case.
By acknowledging the imperfect title of the heirs of Juan Bartolome, the State no longer has a cause of action for reversion because the subject realty is already of private ownership
III. No, the subject lot is not a public domain.
The subject lot already acquired a private character even before the State granted the free patent application of respondent Anna Ramirez Lontok upon looking the records.
The Republic admitted the fact of the open, continuous and adverse possession of the heirs of Juan Bartolome and their predecessors-in-interest for more than 30 years.
IV. No, the Director of Lands has no Jurisdiction over the property.
The Director of Lands loses its jurisdiction over the property when the property is been acquired by a private individual by operation of law. Thus, the State has no title over the occupants and no longer possess a right to initiate an action or pray for reversion because the realty had already been acquired and no longer forms part of the public domain.
V. Yes, dismissal of the subject complaint to be improper.
To recall, the Republic initiated this complaint upon a finding of fraud in the application of a free patent. The authority to file an action in the event of fraud in the application of free patents is based on Sec. 91 of the Public Land Act
Sec. 91 expressly provides for the automatic cancellation of the applications filed on the ground of fraud and misrepresentation. This Court held that it may still validly initiate a complaint for nullification of patents and titles in order to maintain the integrity of the land registration process
Final Order of the Court:
Supreme Court remanded this case to the court of origin for further proceedings on whether fraud attended the application for free patent of respondent Anna Ramirez Lontok.
Lesson of this case:
The State shall remember that it loses its cause of action, in terms of land, when the said land was acquired by a private individual, following the standards by law. But the said land can still be subject to complaints concerning the validity of the patents even if it is already given a title because Section 91 of Public Land Act so provides.
Full text of the case: https://juanbatas.files.wordpress.com/2021/02/gr_198832_2021.pdf
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Spouses Zepeda v. China Banking Corp.
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Heirs of Santiago v. Heirs of Santiago
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