REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE DIRECTOR OF LANDS, PETITIONERS, VS. THE HON. ANDRES REYES, PRESIDING JUDGE, BRANCH VI, COURT OF FIRST INSTANCE OF RIZAL, GODOFRED…

Republic versus Reyes

The Case

This is a petition for certiorari with preliminary injunction brought by the Republic of the Philippines, represented by the Director of Lands, against Judge Andres Reyes, presiding judge of Branch Six of the Court of First Instance of Rizal, and against the private respondents who obtained free patents over two parcels of land in Taguig, Rizal. The Republic asks the Supreme Court to annul the trial court's order of December 16, 1968, which set aside earlier orders and denied the Director of Lands' motion to reopen proceedings. The case matters because it tests whether a judgment that has long become final and fully executed may be annulled by another branch of the same court on grounds of alleged lack of jurisdiction and fraud, and because it settles that titles issued over non-disposable public land, here portions of Laguna de Bay, cannot be shielded by the doctrine of indefeasibility even in the hands of alleged innocent purchasers or mortgagees.

Procedural History

The Director of Lands filed two separate complaints before the Court of First Instance of Rizal, docketed as Civil Cases Nos. 6747 and 6748, for the cancellation of the free patents and original certificates of title issued to Godofredo Eusebio and Urbano Lara. Summons and copies of the complaints were served on the defendants on August 16, 1961. For failure to file answers, the trial court declared them in default on November 25, 1961, and on October 6, 1962 rendered separate decisions declaring the patents and titles null and void and ordering the Register of Deeds to cancel them. No reconsideration or appeal was taken, and the decisions became final and executory.

Almost five years later, on June 3, 1967, Eusebio and Lara, this time as plaintiffs, instituted Civil Case No. 10047 against the Director of Lands for the annulment of the October 6, 1962 decisions, alleging lack of jurisdiction over their persons and fraud. The Director of Lands was declared in default despite improper service of summons, and on July 6, 1967 Branch Six rendered a decision declaring the earlier decisions null and void and ordering the reinstatement of the patents and titles. The Director of Lands then filed a motion to admit a petition to reopen proceedings, which Branch Six granted on May 8, 1968, denied reconsideration on June 29, 1968, and denied a second reconsideration on August 27, 1968. On December 16, 1968, however, the court granted a third motion for reconsideration, set aside its prior orders, and denied the motion to reopen, ruling that the petition was not the proper remedy and that the Director of Lands had lost his personality when declared in default. Hence this petition for certiorari before the Supreme Court.

Facts

On April 17, 1956, Urbano Lara and Godofredo Eusebio filed free patent applications with the Bureau of Lands over two lots in Napindan, Taguig, Rizal, with areas of 10.3629 hectares and 15.2892 hectares. The applications were approved on June 14, 1956, and free patents were issued on June 16, 1956, then transcribed and registered on June 21, 1956 as Original Certificates of Title Nos. 140 and 139.

A subsequent investigation by the Anti-Graft and Corruption Board of the Bureau of Lands revealed that the patented lots were actually under water and formed part of Laguna de Bay. Neither patentee was able to occupy or possess the lots, and there were no signs of cultivation or improvement. On March 16 and March 22, 1960, Lara and Eusebio executed separate affidavits admitting non-compliance with the requirements of the Public Land Act and expressly agreeing to the cancellation of their patents and titles.

After the decisions of October 6, 1962 became final, the Register of Deeds advised the patentees to surrender their owner's duplicates, and they replied that these had long been surrendered to the Bureau of Lands. Yet on July 3, 1967, before the promulgation of the decision in Civil Case No. 10047, Eusebio and Lara sold the lots for 10,000 pesos each to Gil Venzuela, Rodolfo Cenidoza, and Ramon Orosa. Upon the decision becoming final, transfer certificates were issued in the buyers' names, then transferred to the Orosa spouses for 25,000 pesos each, and finally mortgaged to the Philippine Commercial and Industrial Bank for a loan of 800,000 pesos.

Issues

• Whether or not a decision that has long become final and executed may be annulled on the grounds that the court lacked jurisdiction over the persons of the defendants and that the decision was procured through fraud.
• Whether or not the trial court acquired jurisdiction over the persons of Eusebio and Lara in the earlier cases.
• Whether or not one branch of the Court of First Instance may annul the final judgment of another branch of concurrent jurisdiction.
• Whether or not the buyers and the mortgagee bank may be protected as innocent purchasers for value of land forming part of Laguna de Bay.

Applicable Provisions

Article VIII, Section 5 of the 1987 Constitution, as quoted in the decision, provides:

The Supreme Court shall have exclusive jurisdiction to review, revise, reverse, modify or affirm on appeal, as the law or rules of court may provide, final judgments and decrees of the inferior courts as herein provided.

This provision anchors the rule that review of final judgments belongs to the Supreme Court by appeal, not to a co-equal branch by collateral attack.

Ruling

On the first issue, the Court held that the petition is impressed with merit. Once a judgment becomes final, the issues are laid to rest, and absent a showing that the respondents were deprived of due process or that the judgment was procured by extrinsic or collateral fraud, the judgment can no longer be set aside. The filing of Civil Case No. 10047 was therefore improper.

On the second issue, the Court found that jurisdiction over the persons of Eusebio and Lara was validly acquired, since the sheriff's returns showed personal service of summons and copies of the complaints on August 16, 1961 at their recorded address in Bambang, Pasig, Rizal. The Court stated the rule:

Jurisdiction over the person of a defendant is acquired when he actually receives the summons.

On the third issue, the Court invoked the doctrine of non-interference, holding that the judgment of a court of competent jurisdiction may not be opened, modified, or vacated by any court of concurrent jurisdiction. A judge of one branch should not annul the order of a judge of another branch of the same court; any branch that attempts to annul such a judgment either exceeds its jurisdiction or acts with grave abuse of discretion amounting to lack of jurisdiction.

On the fourth issue, the Court held that the buyers and the bank acquire no protection, because the lots form part of Laguna de Bay and are neither agricultural nor disposable. Any false statement in an application for public land ipso facto produces cancellation of the title granted, even after issuance of the certificate, and the doctrine of indefeasibility of Torrens title does not apply to a free patent secured through fraud. Void free patents do not divest the State of its ownership nor change the public character of the land. The law on innocent purchasers for value does not apply insofar as non-disposable public lands are concerned, and the bank, though an innocent mortgagee for value, acquires no protection under the Land Registration Law.

Doctrine

A judgment that has become final and executory may not be annulled by another branch of concurrent jurisdiction; relief must be sought through the remedies provided by the Rules of Court, such as relief from the order of default or appeal, and the doctrine of finality rests on public policy and sound practice. Jurisdiction over the person of a defendant is acquired when he actually receives the summons. Titles issued over non-disposable public land, such as portions of Laguna de Bay, are void and may be cancelled even in the hands of alleged innocent purchasers for value or innocent mortgagees, because the doctrine of indefeasibility of Torrens title does not shield a free patent secured through fraud, and void patents do not divest the State of ownership nor convert public land to private.

Disposition

The Supreme Court granted the petition, reversed and set aside the July 6, 1967 decision and the December 16, 1968 order, reinstated the October 6, 1962 decisions, directed the Register of Deeds to cancel all certificates of title issued in connection with Civil Case No. 10047, and set aside the real estate mortgage in favor of the Philippine Commercial and Industrial Bank, without prejudice to payment of the indebtedness to the bank.

Remember This

Memorize this line: a final judgment may not be annulled by a co-equal branch, and a Torrens title over non-disposable public land is void even in the hands of an innocent purchaser. Examiners use this case to test the doctrine of finality of judgment, the non-interference rule among branches, and the limits of the innocent purchaser and mortgagee doctrines over inalienable public land.