G.R. No. 91486. September 10, 2003 (Case Brief / Digest)

### Title:
**Alberto G. Pinlac, et al. vs. Court of Appeals, et al.**: A Case on the Annulment of Judgment and the Protection of Public and Private Interests in Land Title Disputes

### Facts:
The case originated from a Petition for Quieting of Title filed by petitioners over three vast parcels of land, designated as Lot Nos. 1, 2, & 3, claiming ownership through extraordinary prescription. The trial court, in a Partial Decision dated March 21, 1988, ruled in favor of the petitioners against defaulting respondents, including owners of the Vilma Subdivision located within Lot No. 2. The court declared petitioners as the absolute owners and ordered the cancellation of certain titles.

The defaulted title owners of Vilma Subdivision challenged the Partial Decision by filing a Petition to Annul with the Court of Appeals, which ruled in their favor on the grounds of defective service of summons, thereby nullifying the trial court’s decision. Petitioners’ subsequent motion for reconsideration failed, leading to this certiorari plea.

The Supreme Court initially denied the petition, reaffirming the appellate court’s judgment. Upon petitioners’ further motion centered on Lot No. 3, the Supreme Court issued a resolution partially granting their plea, thus reinstating certain portions of the trial court’s decision concerning Lot No. 3.

The Republic of the Philippines, represented by the Land Registration Authority, later intervened, emphasizing the need to protect public interest on lands within the disputed area marked for government projects and claimed as part of the National Government Center pursuant to Proclamation No. 1826.

### Issues:
1. Whether the Court of Appeals correctly annulled the trial court’s Partial Decision due to defective summons.
2. Whether the Supreme Court should consider the Republic’s late intervention in the interest of justice and public interest.
3. The validity and scope of OCT No. 333 as it pertains to Lot No. 3 and its implications on public and private landholdings.
4. The application of the doctrine of stare decisis on the validity of OCT No. 333 and derived titles.

### Court’s Decision:
The Supreme Court partly granted the Republic’s Petition-In-Intervention. It modified its previous resolution by annulling the trial court’s decision insofar as it concerned Lots No. 2 and 3, acknowledging the defective service of summons and the importance of protecting public interest alongside specific private properties. The Court recognized the validity of OCT No. 333, adhering to the principle of stare decisis, yet it cautioned against extending its area beyond established measures due to potential violations of due process for adjacent landowners.

### Doctrine:
– The doctrine of stare decisis was applied to reaffirm the validity of OCT No. 333.
– The case underscored procedural doctrines concerning the timing and grounds for intervention and annulment of judgment, emphasizing justice and equity over procedural technicalities.

### Class Notes:
– **Stare Decisis**: Once a principle of law has been established by the Supreme Court, it should be followed in similar cases.
– **Annulment of Judgment**: A judgment may be annulled on grounds such as defective summons, ensuring no party is deprived of due process.
– **Petition for Intervention**: Allowable when it serves the interest of justice and public interest, even after a decision by the trial court.
– **Protection of Public Interest in Property Disputes**: The state or its agencies may intervene in disputes affecting national projects or interests.
– Procedural rules are designed to ensure justice, not hinder it.

### Historical Background:
This case delves into complex issues of land ownership, title validity, and the legal mechanisms to contest or affirm land titles within the Philippines. It highlights the tension between individual property rights and the necessity of government to intervene in matters of public interest. Moreover, it reflects on the enduring implications of historical land titles (like OCT No. 333) on contemporary property disputes and urban development policies.


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