The Supreme Court (SC) has directed the Court of Appeals (CA) to review the land dispute case involving the 1,342-hectare Maysilo Estate, which stretches across four cities of Metro Manila.
In a 46-page resolution, the High
Tribunal overturned an earlier CA ruling on the issue, remanding the case to a special division in the appellate court to ascertain which of the conflicting claims of title over the land should prevail.
The Supreme Court appointed CA Associate Justice Josefina Guevara-Salonga to head the special court to try the case with Justices Lucas Bersamin and Japar Dimaampao as members of the special division.
The High Court directed the CA body to submit its findings and recommendations within three months.
In the resolution penned by Associate Justice Dante Tinga, the SC noted the numerous conflicting claims on a vast tract of land that virtually occupies the northern half of Metro Manila.
The SC decided against ruling on the issue noting that, “the stability of the country’s Torrens (land titling) system is menaced by the infestation of fake land titles and deeds.”
“Any decision of this Court that breathes life into spurious or inexistent titles all but contributes to the blight. On the contrary, the judicial devotion is towards purging the system of illicit titles, concomitant to our base task as the ultimate citadel of justice and legitimacy,” the High Court said.
The CA special panel was formed to determine which of the claims of the contending parties are legally entitled from Original Certificate of Title (OCT) No. 994.
The SC noted the conflicting claims of CLT Realty Development Corp. and the late Jose B. Dimson and Manotok Estate Corp. (Manotoks), the Araneta Institute of Agriculture Inc. (Araneta) on the land whose titles stemmed from OCT 994.
The remand was made after motions for reconsideration filed by the Manotoks and Araneta, who both sought a reversal of the Nov. 29, 2005 SC ruling that effectively nullified the land titles in their names and denied their petitions against the CA decision on the same case.
The Manotoks and Araneta raised the issue before the SC, appealing the CA rulings that also affirmed the lower court decisions awarding to CLT and Dimson the properties being claimed by the Manotoks and Araneta.
Their petitions involve claims over a 1,342-hectare tract of land that had been subdivided and titled from OCT 994.
In 1979, Dimson filed with the then Court of First Instances of Rizal, in Caloocan City a complaint for recovery of possession and damages against Araneta.
Dimson alleged he was the absolute owner of part of the Maysilo Estate in Malabon covered by TCT No. R-15169 of the Registry of Deeds of Caloocan City.
The Caloocan court ruled in Dimson’s favor, prompting Araneta to appeal the case with the CA, which, in turn, affirmed the lower court’s decision. Araneta brought the case to the SC when its motion for reconsideration was also denied by the CA.
In 1992, CLT Realty Development Corp. sought to recover from the Manotoks Lot 26 of the Maysilo Estate before the Caloocan City Regional Trial Court, Branch 129.
The lower court ruled in favor of CLT, prompting the Manotoks to appeal to the CA, which also affirmed the lower court’s decision.
When their motion for reconsideration was also denied, the Manotoks elevated the case to the SC.
Both petitions involved challenges against the validity of the parties’ separate titles to portions of the greater Maysilo Estate, which covered parts of Caloocan City, Malabon, Quezon City and Valenzuela.
In 2002, the government sought intervention in the cases and was allowed by the SC.
On Nov. 29, 2005, the SC’s Third Division reaffirmed its 2005 decision, which upheld the CA decision and resolutions.
Both the Manotoks and Araneta filed their motions for reconsideration before the SC.
The trial began on June 5, 2006, and the High Court scheduled the oral argument on the case on Aug. 1, 2006.
What emerged from the oral argument was that there was in fact only one OCT 994 and that its true date was May 3, 1917, the date it was received for transcription by the Registry of Deeds, the entry in the registration book being the original certificate of title.
The titles of CLT and Dimson, however, purportedly originated from the same OCT No. 994 registered earlier on April 19, 1917.
The High Court noted the conflicting issue of dates on the same mother title.
Given this essential clarification, the SC said there is no sense in affirming the 2005 decision, which sustained the complaints for annulment of title and/or recovery of possession filed by CLT and Dimson.
The High Tribunal, however, concluded that there is only one OCT No. 994 and any transfer certificate of title emanating from the mother title dated April 17, 1917 is void, and “inexistent.”
The High Court did not apply its 1992 decision in MWSS versus CA, and in other similar cases stemming from the same OCT No. 994.
The SC said MWSS and Gonzaga decisions have virtually become “functus officio except on the basis of the ‘law of the case’ doctrine.”
In its resolution, the SC said the conclusions will serve to guide the CA in hearing these cases on remand.
The High Court said remanding the case to the CA is “not a deviant procedure” since the appellate court has jurisdiction of being a trier of facts.
“The Court of Appeals generally has the authority to review findings of fact. Its conclusions as to findings of fact are generally accorded great respect by this Court. It is a body that is fully capacitated and has a surfeit of experience in appreciating factual matters, including documentary evidence,” Tinga wrote in the SC decision.
Aside from Tinga, among the justices who voted to remand the case to the CA were Senior Associate Justice Leonardo Quisumbing, Justices Ma. Alicia Austria-Martinez, Conchita Carpio Morales, Adolf Azcuna, Minita Chico-Nazario and Teresita Leonardo-de Castro.
Justice Angelina Sandoval-Gutierrez led the dissenting opinion with Justices Presbitero Velasco Jr. and Ruben Reyes.
Justice Renato Corona voted to grant the motions for reconsideration and annulment of titles of Transfer of Certificate Titles (TCTs) of CLT and the heirs of Dimson.
Chief Justice Reynato Puno inhibited in the deliberations due to relationship to one of the counsels. Justices Antonio Eduardo Nachura, Consuelo Ynares-Santiago and Antonio Carpio also did not take part in the voting.