Republic of the Philippines vs. Mangotara

An action for quieting of title, as a special proceeding under Rule 63 of the Rules of Court, may properly include the determination of heirship, filiation, and status when such issues are indispensable to resolving the parties' respective claims to the property. Additionally, the Republic's right to seek reversion of public land unlawfully included in a certificate of title is not barred by prescription, and a writ of preliminary injunction may issue to stay execution of a Regional Trial Court judgment in an ejectment case pending appeal to the Court of Appeals when substantial considerations — including public interest — so warrant.

Doña Demetria Cacho applied in the early 1900s for registration of two parcels of land in what is now Iligan City: a small parcel (Lot 1, 0.36 hectares) and a larger parcel (Lot 2, 37.87 hectares). The United States Government opposed, claiming the land formed part of a military reservation. In 1912, the land registration court adjudicated only the southern cultivated portion of Lot 2 to Doña Demetria, requiring a new survey and a deed from Datto Darondon renouncing his rights. The Supreme Court affirmed this decision in 1914. Decrees of registration were issued in 1913 and 1915. Decades later, in 1978, a man named Teofilo Cacho petitioned for reconstitution of the lost decrees, claiming to be Doña Demetria's sole heir. The Supreme Court ultimately granted reconstitution in the 1997 Cacho case. Original Certificates of Title Nos. 0-1200 (a.f.) and 0-1201 (a.f.) were issued in Doña Demetria's name on October 15, 1998. Subsequently, competing claims of heirship, governmental expropriation, ejectment of a power utility, and allegations that the OCTs covered land beyond what was adjudicated in 1914 spawned the four cases consolidated in this decision.

The 1914 Cacho Case: In the early 1900s, Doña Demetria Cacho sought registration of two parcels in Iligan, Moro Province — Lot 1 (0.36 hectares) and Lot 2 (37.87 hectares). The United States Government opposed, asserting the land formed part of the Camp Overton military reservation. On December 10, 1912, the land registration court adjudicated only the southern cultivated portion of Lot 2 to Doña Demetria, conditioned upon presentation of (a) a new survey plan delineating that portion, and (b) a deed from Datto Darondon renouncing his rights over Lot 1. The Supreme Court affirmed in toto on December 10, 1914. Decree No. 10364 (for Lot 1) was issued May 9, 1913; Decree No. 18969 (for Lot 2) was issued July 8, 1915.

The 1997 Cacho Case: In 1978, Teofilo Cacho filed a petition for reconstitution of the lost decrees, claiming he was Doña Demetria's sole heir. The Republic and National Steel Corporation opposed. The Supreme Court ultimately granted reconstitution, finding that the decrees had been validly issued and attained finality; that requiring a new survey would violate res judicata; and that Teofilo's Affidavit of Adjudication executed before the Philippine Consulate in Chicago enjoyed presumption of regularity. Re-issued Decree Nos. N-219464 and N-219465 led to OCT Nos. 0-1200 (a.f.) and 0-1201 (a.f.) in Doña Demetria's name, entered December 4, 1998.

The Expropriation Case (G.R. No. 170375): In 1983, the Iron and Steel Authority filed an expropriation complaint against Maria Cristina Fertilizer Corporation over 30.25 hectares reserved under Presidential Proclamation No. 2239. When ISA's charter expired, the Republic substituted as plaintiff per Supreme Court directive in Iron and Steel Authority v. Court of Appeals. The Republic later sought to implead Teofilo Cacho, Demetria Vidal, Landtrade, and AZIMUTH via supplemental complaint, alleging that their claimed lands overlapped the expropriated area. RTC-Branch 1 dismissed the complaint in July 2005 for (a) failure to implead indispensable parties (the owners), and (b) forum shopping, as the Republic simultaneously filed a reversion case.

The Quieting of Title Case (G.R. Nos. 178779 and 178894): Demetria Cacho Vidal alleged she was Doña Demetria's sole heir — the daughter of Francisco Cacho Vidal, who was the only child of Doña Demetria and Dionisio Vidal. AZIMUTH joined as Vidal's successor-in-interest under a 1998 Memorandum of Agreement. Teofilo Cacho and Atty. Godofredo Cabildo opposed, asserting the 1997 Cacho case had already recognized Teofilo's heirship. Landtrade intervened, claiming ownership of 27.03 hectares purchased from Teofilo via a 1996 Deed of Absolute Sale. Teofilo and Atty. Cabildo failed to present any evidence at trial. RTC-Branch 3 declared Vidal the sole heir, Teofilo an impostor, and awarded damages. The Court of Appeals affirmed in toto on January 19, 2007.

The Ejectment Case (G.R. Nos. 170505, 173355-56, 173563-64): NAPOCOR had occupied two parcels in Iligan City since 1952, where it built the Overton Sub-station and Agus 7 Warehouse. TRANSCO took over transmission functions under the EPIRA law. In 2003, Landtrade filed an unlawful detainer complaint, claiming ownership under the 1996 Deed of Sale from Teofilo. The MTCC ruled for Landtrade in February 2004, ordering NAPOCOR and TRANSCO to vacate and pay ₱500,000 monthly rent retroactive to 1978 plus ₱156 million in back rentals. NAPOCOR and TRANSCO appealed to the RTC but did not file a supersedeas bond or deposit rent, claiming statutory exemption. RTC-Branch 5 granted execution pending appeal, but the Court of Appeals annulled the execution order, ruling NAPOCOR was exempt. Later, after the RTC-Branch 1 affirmed the MTCC decision on appeal, the Court of Appeals granted Landtrade's motion for execution pending appeal and denied NAPOCOR and TRANSCO's application for preliminary injunction.

The Reversion Case (G.R. No. 173401): The Republic sought cancellation of OCT Nos. 0-1200 and 0-1201 and reversion, alleging that the OCTs covered areas far larger than those adjudicated to Doña Demetria in 1914 — the entire 37.87 hectares instead of only the southern portion, and that the technical descriptions referenced pre-1914 surveys. RTC-Branch 4 dismissed the complaint in December 2005 on grounds of: (a) no cause of action; (b) res judicata (barred by the 1914 and 1997 Cacho cases); (c) prescription under Section 32 of P.D. 1529; and (d) forum shopping.

In G.R. No. 170375 (Republic — Expropriation):

• Non-joinder is not a ground for dismissal: The Republic argued that Rule 3, Section 11 of the Rules of Court explicitly provides that misjoinder or non-joinder of parties is not a ground for dismissal; parties may be added at any stage. The proper remedy was to order impleader, not dismissal.

• MCFC is a proper party: The Republic maintained that MCFC was impleaded as an occupant with possessory rights, not as owner. Rule 67, Section 1 requires joining "all persons owning or claiming to own, or occupying, any part thereof." Letter of Instructions No. 1277 expressly recognized MCFC's occupancy rights.

• No forum shopping: The Republic contended that expropriation and reversion are distinct remedies with different causes of action and reliefs. Expropriation sought MCFC's possessory rights; reversion sought cancellation of titles unlawfully including public land. Filing both did not constitute forum shopping.

In G.R. Nos. 178779 and 178894 (Landtrade, Teofilo Cacho, Atty. Cabildo — Quieting of Title):

• Lack of jurisdiction over heirship: Petitioners argued that the RTC lacked jurisdiction to determine Vidal's status, filiation, and heirship in an action for quieting of title. Such declarations must be made exclusively in special proceedings for settlement of estate under Rule 90, citing Agapay v. Palang and Heirs of Yaptinchay v. Del Rosario.

• No cause of action: Petitioners maintained that Vidal had no legal or equitable title to the subject properties since the 1997 Cacho case had conclusively established Teofilo's identity and heirship. The concept of cause of action did not apply because Vidal lacked any title to quiet.

• Insufficient evidence of filiation: Petitioners challenged the probative value of Vidal's baptismal certificate, arguing it is not conclusive proof of filiation.

• Prescription: Landtrade asserted that the quieting of title action had prescribed, having been filed in 1998, more than 10 years after Teofilo executed his Affidavit of Adjudication in 1985.

In G.R. No. 170375 (MCFC — Expropriation):

• Republic lacked legal personality: MCFC countered that the Republic failed to move for execution of the ISA case judgment within the five-year prescriptive period, and the only remedy was an independent action to revive judgment. The substitution was therefore void.

• Forum shopping and inconsistent positions: MCFC argued the Republic committed forum shopping by filing both expropriation and reversion cases, and took contradictory positions — conceding lack of ownership in expropriation while asserting ownership in reversion.

In G.R. Nos. 178779 and 178894 (Vidal and AZIMUTH — Quieting of Title):

• Jurisdiction properly exercised: Respondents maintained that the RTC had jurisdiction over the subject matter (assessed value exceeding ₱35 million) and acquired jurisdiction over the persons of Teofilo and Landtrade when they filed answers. The determination of heirship was an exercise of that jurisdiction, not a jurisdictional defect.

• Quieting of title is a special proceeding: Respondents argued that unlike actions for reconveyance (in Agapay and Yaptinchay), quieting of title is governed by Rule 63 on declaratory relief and similar remedies — a special proceeding where the court must determine rights of parties, necessarily including heirship when title is claimed by succession.

• The 1997 Cacho case did not decide ownership: Respondents stressed that reconstitution proceedings do not adjudicate ownership; the 1997 case merely ordered re-issuance of lost decrees. Teofilo's heirship was never the lis mota of that case.

• No prescription: The action was a real action prescribing in 30 years under Article 1141 of the Civil Code. Only 20 years had elapsed from Teofilo's first adverse claim in 1978.

In G.R. Nos. 173355-56 and 173563-64 (NAPOCOR and TRANSCO — Ejectment):

• Exception to immediate execution: NAPOCOR and TRANSCO argued that nothing in Rule 70, Section 21 bars application of Rule 58 on preliminary injunction. The Court of Appeals retained power to enjoin execution when circumstances warrant, citing Benedicto v. Court of Appeals.

• Public interest and irreparable injury: Respondents contended that ejecting TRANSCO from the Overton Sub-station would disrupt power supply to a large portion of Iligan City, the two Lanao provinces, and nearby areas, causing irreparable harm that cannot be compensated by damages.

• Cloud on Landtrade's title: Respondents pointed to the pending quieting of title case, where the RTC had already declared Teofilo — Landtrade's predecessor — as having no rights to the property.

• Proper mode of appeal: Whether the Republic's filing of consolidated petitions under both Rules 45 and 65 was procedurally proper.

• Hierarchy of courts: Whether direct resort to the Supreme Court violated the doctrine of hierarchy of courts.

• Dismissal for non-joinder: Whether the RTC-Branch 1 erred in dismissing the expropriation complaint for failure to implead the property owner as an indispensable party.

• Proper parties in expropriation: Whether MCFC, as occupant, was a proper party-defendant in the expropriation case.

• Forum shopping (Expropriation vs. Reversion): Whether the Republic committed forum shopping by simultaneously instituting expropriation and reversion proceedings over the same parcels of land.

• Jurisdiction to determine heirship: Whether the RTC-Branch 3 had jurisdiction to resolve issues of Vidal's status, filiation, and heirship in an action for quieting of title.

• Quieting of title versus ordinary civil action: Whether the Agapay and Yaptinchay doctrines barring declaration of heirship in ordinary civil actions apply to actions for quieting of title.

• Effect of 1997 Cacho case: Whether the 1997 Cacho case conclusively established Teofilo's status as Doña Demetria's sole heir.

• Sufficiency of evidence of filiation: Whether Vidal presented sufficient evidence to prove her status as Doña Demetria's granddaughter and sole heir.

• Prescription of quieting of title: Whether Civil Case No. 4452 was barred by prescription or laches.

• Execution pending appeal (Rule 70, Section 19): Whether NAPOCOR's statutory exemption from supersedeas bonds extended to the requirement of periodical deposit of rent to stay execution.

• Mootness: Whether Landtrade's petition (G.R. No. 170505) had become moot given the RTC had already resolved the appeal.

• Preliminary injunction under Rule 70, Section 21: Whether the Court of Appeals committed grave abuse of discretion in refusing to enjoin execution of the RTC ejectment judgment pending appeal.

• Cause of action for reversion: Whether the Republic's complaint in Civil Case No. 6686 stated a valid cause of action for cancellation of titles and reversion.

• Res judicata (Reversion): Whether the 1914 and 1997 Cacho cases barred the reversion complaint by res judicata.

• Forum shopping (Reversion): Whether the Republic committed forum shopping in filing the reversion complaint.

• Prescription of reversion: Whether the Republic's action for reversion was barred by prescription under Section 32 of P.D. 1529 or the Civil Code.

• Proper mode of appeal: The filing of consolidated petitions under both Rules 45 and 65 was improper, the remedies being mutually exclusive. However, in the interest of justice, the Consolidated Petitions were treated as a Petition for Review on Certiorari under Rule 45, having been filed within the reglementary period. The Court distinguished the MWSS case, which did not authorize such combined petitions.

• Hierarchy of courts: Direct filing with the Supreme Court did not violate the hierarchy of courts doctrine. The petition raised pure questions of law — whether dismissal for non-joinder and forum shopping was proper — which fall within the Court's direct review under Rule 45.

• Dismissal for non-joinder: The dismissal was erroneous. Rule 3, Section 11 explicitly provides that misjoinder or non-joinder of parties is not a ground for dismissal. Even assuming the property owner was an indispensable party, the remedy was to order impleader, not dismissal. The RTC-Branch 1 failed to first require the Republic to implead the alleged owners before dismissing the complaint.

• Proper parties in expropriation: MCFC was a proper party. Rule 67, Section 1 requires joining "all persons owning or claiming to own, or occupying, any part thereof or interest therein." MCFC's occupancy rights were expressly recognized in Letter of Instructions No. 1277. Just compensation is not due to the owner alone but to all persons with lawful interest, including occupants and possessors.

• Forum shopping (Expropriation vs. Reversion): No forum shopping existed. The elements of litis pendentia were absent: there was no identity of rights asserted and reliefs prayed for. Expropriation aimed to acquire MCFC's occupancy rights for public purpose; reversion sought cancellation of OCTs that allegedly included land beyond what was adjudicated. The Republic did not take inconsistent positions — both actions were premised on the assertion that the land remained part of the public domain, and Rule 67, Section 1 permits expropriation even when title appears to be in the Republic but is occupied by private individuals.

• Jurisdiction to determine heirship: The RTC-Branch 3 had jurisdiction over the subject matter (assessed value exceeding ₱35 million under B.P. Blg. 129, Section 19[2]) and over the persons of Teofilo (who filed an answer) and Landtrade (allowed to intervene). Where jurisdiction over the person and subject matter exists, resolution of all other questions — including heirship — is an exercise of that jurisdiction, and any error is merely an error of judgment correctible on appeal.

• Quieting of title versus ordinary civil action: The Agapay and Yaptinchay cases were distinguished as involving actions for reconveyance — ordinary civil actions — where declarations of heirship are improper. An action for quieting of title is a special proceeding under Rule 63, where the court is precisely tasked to determine the rights of contending parties to real property. The cloud Vidal sought to remove was Teofilo's adverse claim of title as Doña Demetria's heir. Determining heirship was indispensable to resolving title. Even assuming the Agapay rule applied, exceptions recognized in Portugal v. Portugal-Beltran, Heirs of Gabatan v. Court of Appeals, and Fidel v. Court of Appeals would apply where: (a) no other property required administration proceedings; (b) the parties voluntarily submitted the issue; and (c) it was more practical and expeditious.

• Effect of 1997 Cacho case: The 1997 Cacho case did not conclusively establish Teofilo's heirship. Reconstitution/re-issuance proceedings do not adjudicate ownership; they merely restore the lost instrument to its original form. The Court's statement on Teofilo's heirship — based on the Affidavit of Adjudication's presumption of regularity — was obiter dictum, addressing only his legal interest to file the petition. A certificate of title is merely evidence of ownership, not ownership itself.

• Sufficiency of evidence of filiation: Vidal's baptismal certificate, birth certificate, the "Cacho" family book, family tree, and her own uncontroverted testimony — all unrebutted by Teofilo, who presented no evidence — sufficiently established her filiation. Under Article 172 of the Family Code, filiation may be proved by "any other means allowed by the Rules of Court," including baptismal certificates. The trial court's factual findings, affirmed by the Court of Appeals, were supported by substantial evidence and are binding on the Supreme Court.

• Prescription of quieting of title: The action had not prescribed. Quieting of title is a real action prescribing in 30 years under Article 1141 of the Civil Code. From Doña Demetria's death in 1974 to the filing in 1998, only 24 years passed. Even measuring from Teofilo's first adverse claim (the 1978 reconstitution petition), only 20 years elapsed. Landtrade could not claim acquisitive prescription: it was not a possessor in good faith, having bought from a non-registered owner (Teofilo) through an attorney-in-fact, and portions of the property were occupied by NAPOCOR — a circumstance demanding further inquiry.

• Execution pending appeal (Rule 70, Section 19): Landtrade's petition (G.R. No. 170505) was rendered moot and academic because the RTC-Branch 1 had already resolved the appeal in December 2005. Rule 70, Section 19 applies only when the MTCC judgment is pending appeal before the RTC; once the RTC decides the appeal, Section 21 governs. The Court noted, but did not apply to this case, its recent reversal of NAPOCOR's exemption from filing fees and bonds under A.M. No. 05-10-20-SC (Resolutions dated October 27, 2009 and March 10, 2010).

• Preliminary injunction under Rule 70, Section 21: The Court of Appeals committed grave abuse of discretion in refusing to enjoin execution. While Rule 70, Section 21 makes RTC judgments immediately executory, it does not divest the appellate court of its power under Rule 58 to issue preliminary injunctions when circumstances warrant. Substantial considerations compelled an injunction: (a) the title of Landtrade — on which its possessory claim rested — had been nullified by the quieting of title judgment declaring Teofilo an impostor; (b) ejecting TRANSCO from the Overton Sub-station would disrupt power supply to a large portion of Mindanao, causing irreparable public harm; and (c) payment of ₱156 million in back rentals plus ₱500,000 monthly would imperil a public utility's operations.

• Cause of action for reversion: The complaint sufficiently stated a cause of action. The Republic alleged that OCT Nos. 0-1200 (a.f.) and 0-1201 (a.f.) covered areas far larger than those adjudicated in 1914 — the entire 37.87 hectares instead of only the southern portion, and that technical descriptions referenced pre-1914 surveys. Under the Regalian doctrine, land not clearly within private ownership is presumed to belong to the State. Unlawful inclusion of public land in a certificate of title is a valid ground for reversion, even absent fraud. Reversion is not limited to fraud but extends to titles void for violation of grant conditions or lack of jurisdiction. The complaint need not allege that the Director of Lands requested reversion; Section 101 of the Public Land Act confers primary authority on the Solicitor General.

• Res judicata (Reversion): Neither the 1914 nor the 1997 Cacho case barred the reversion complaint. Bar by prior judgment did not apply because the causes of action differed: the 1914 case was a land registration proceeding (a special proceeding establishing ownership); the 1997 case was a reconstitution proceeding (restoring lost decrees); the reversion case sought cancellation of titles for unlawful inclusion of public land. Conclusiveness of judgment did not apply because the Republic did not seek to re-litigate whether Doña Demetria was awarded land — it insisted on strict adherence to the 1914 judgment, arguing the OCTs covered land beyond what was adjudicated. The 1997 case only settled the existence and loss of the decrees, not the validity of the titles.

• Forum shopping (Reversion): No forum shopping existed. Since the 1914 and 1997 cases did not constitute res judicata to the reversion complaint, the elements of litis pendentia were not present.

• Prescription of reversion: The Republic's action was not barred by prescription. The rule is elementary: prescription does not run against the State. Public land fraudulently or unlawfully included in certificates of title may be recovered by reversion regardless of the lapse of time. Section 101 of the Public Land Act provides a continuing remedy. The indefeasibility of a Torrens title does not attach to void titles; registration under the Torrens system does not vest title but merely confirms an existing one. The one-year period under Section 32 of P.D. 1529 for reviewing decrees of registration applies to review on grounds of fraud; it does not bar the State from seeking reversion of public land unlawfully included.

• Distinction between jurisdiction and exercise of jurisdiction — Jurisdiction is the authority to decide a cause, not the decision rendered. Where there is jurisdiction over the person and the subject matter, resolution of all other questions is an exercise of that jurisdiction. Errors committed in that exercise are errors of judgment, correctible on appeal, not jurisdictional defects. Applied to affirm that the RTC properly exercised its jurisdiction in determining heirship in the quieting of title case.

• Quieting of title as a special proceeding — An action for quieting of title under Articles 476-481 of the Civil Code is a special proceeding governed by Rule 63 of the Rules of Court (Declaratory Relief and Similar Remedies), not an ordinary civil action. As such, the concept of cause of action in ordinary civil actions does not strictly apply, and the court must determine the respective rights of the parties to the property, including questions of heirship when title is claimed by succession.

• Exception to the Agapay/Yaptinchay rule on heirship — While declarations of heirship are generally reserved for special proceedings for settlement of estate, they may be made in an action for quieting of title when: (a) the determination of heirship is indispensable to resolving the parties' claims to the property; (b) the parties voluntarily submitted the issue; (c) there is no other property requiring administration proceedings; and (d) it is more practical and expeditious to resolve heirship in the same proceeding. Applied to sustain the RTC's determination that Vidal was Doña Demetria's sole heir.

• Reconstitution does not adjudicate ownership — A petition for reconstitution of title (or re-issuance of decree) does not pass upon ownership of the land. The purpose is merely to reproduce the lost or destroyed instrument in its original form and condition. Any findings on ownership are obiter dictum. A certificate of title is merely evidence of ownership; registration is not a mode of acquiring ownership.

• Reversion not barred by prescription — The State's right to seek reversion of public land unlawfully included in certificates of title is imprescriptible. Prescription does not run against the State. The indefeasibility of a Torrens title does not attach to void titles — those procured through fraud, misrepresentation, or unlawful inclusion of inalienable public land. Section 101 of the Public Land Act (C.A. 141) provides a continuing remedy available to the Republic through the Solicitor General.

• Injunction against execution of RTC ejectment judgment — Although Rule 70, Section 21 of the Rules of Court makes RTC judgments in ejectment cases immediately executory, the appellate court retains power under Rule 58 to issue a writ of preliminary injunction when substantial considerations — including public interest, cloud on the prevailing party's title, and risk of irreparable injury — so warrant. The execution operates without prejudice to the appeal, but equity may restrain its enforcement pending final resolution.

• Proper parties in expropriation — Under Rule 67, Section 1, defendants in expropriation are not limited to property owners. All persons "owning or claiming to own, or occupying" any part of the property must be joined. Occupants with possessory rights, lessees, mortgagees, and vendees in possession are entitled to compensation and are proper parties. Non-joinder of an indispensable party is not a ground for dismissal; the remedy is to order impleader.

• Forum shopping in governmental actions — The simultaneous filing of expropriation and reversion proceedings does not constitute forum shopping. The two actions have distinct causes of action and reliefs: expropriation seeks to acquire possessory or occupancy rights for public use upon payment of just compensation; reversion seeks cancellation of void titles and return of land to the public domain. Rule 67, Section 1 contemplates that expropriation may proceed even when title is in the Republic but occupied by private individuals.

• "Where there is jurisdiction over the person and the subject matter, the decision on all other questions arising in the case is but an exercise of the jurisdiction. And the errors which the court may commit in the exercise of jurisdiction are merely errors of judgment which are the proper subject of an appeal."

• "The Agapay and Yaptinchay cases, as well as the cases of Litam v. Rivera and Solivio v. Court of Appeals, cited in the Yaptinchay case, all arose from actions for reconveyance; while the instant Petitions stemmed from an action for quieting of title. The Court may have declared in previous cases that an action for reconveyance is in the nature of an action for quieting of title, but the two are distinct remedies."

• "It must be borne in mind that the concept of a cause of action in ordinary civil actions does not apply to quieting of title. In declaratory relief, the subject-matter is a deed, will, contract or other written instrument, statute, executive order or regulation, or ordinance. The issue is the validity or construction of these documents. The relief sought is the declaration of the petitioner's rights and duties thereunder."

• "In determining whether allegations of a complaint are sufficient to support a cause of action, it must be borne in mind that the complaint does not have to establish or allege facts proving the existence of a cause of action at the outset; this will have to be done at the trial on the merits of the case."

• "Prescription does not run against the State and its subdivisions. When the government is the real party in interest, and it is proceeding mainly to assert its own right to recover its own property, there can as a rule be no defense grounded on laches or prescription. Public land fraudulently included in patents or certificates of title may be recovered or reverted to the State in accordance with Section 101 of the Public Land Act. The right of reversion or reconveyance to the State is not barred by prescription."

• "A certificate of title that is void may be ordered cancelled. A title will be considered void if it is procured through fraud, as when a person applies for registration of the land under his name although the property belongs to another. In the case of disposable public lands, failure on the part of the grantee to comply with the conditions imposed by law is a ground for holding such title void. The lapse of the one year period within which a decree of title may be reopened for fraud would not prevent the cancellation thereof, for to hold that a title may become indefeasible by registration, even if such title had been secured through fraud or in violation of the law, would be the height of absurdity. Registration should not be a shield of fraud in securing title."

• "Even if RTC judgments in unlawful detainer cases are immediately executory, preliminary injunction may still be granted. There need only be clear showing that there exists a right to be protected and that the acts against which the writ is to be directed violate said right."

• "Reconstitution denotes a restoration of the instrument which is supposed to have been lost or destroyed in its original form or condition. The purpose of the reconstitution of title or any document is to have the same reproduced, after observing the procedure prescribed by law, in the same form they were when the loss or destruction occurred."

• Cacho v. Government of the United States, 28 Phil. 616 (1914) — The foundational 1914 decision whose scope the reversion case sought to enforce. The Court affirmed the LRC judgment granting Doña Demetria only the southern portion of Lot 2. Distinguished in the reversion discussion as not barring re-litigation of the OCTs' validity.

• Cacho v. Court of Appeals, 336 Phil. 154 (1997) — The 1997 Cacho case granting reconstitution of decrees. The Court clarified that this decision only established the existence and loss of decrees, not Teofilo's heirship or the validity of the OCTs.

• Agapay v. Palang, 342 Phil. 302 (1997) — Distinguished. Established that heirship declarations must be made in special proceedings, not in ordinary civil actions for recovery of ownership. Not applied because the present case involved quieting of title, a special proceeding.

• Heirs of Guido Yaptinchay v. Del Rosario, 363 Phil. 393 (1999) — Distinguished similarly to Agapay. Involved an action for reconveyance, an ordinary civil action, unlike quieting of title which is a special proceeding.

• Portugal v. Portugal-Beltran, G.R. No. 155555, August 16, 2005, 467 SCRA 184 — Applied. Recognized exceptions allowing determination of heirship in ordinary civil actions when no other property requires administration proceedings and doing so is more practical and expeditious.

• Heirs of Teofilo Gabatan v. Court of Appeals, G.R. No. 150206, March 13, 2009, 581 SCRA 70 — Applied. Affirmed that heirship may be determined outside special proceedings when parties voluntarily submit the issue and it is more practical to do so.

• Fidel v. Court of Appeals, G.R. No. 168263, July 21, 2008, 559 SCRA 186 — Applied. Held that a party who raised the issue of heirship is estopped from assailing the court's ruling on it.

• Benedicto v. Court of Appeals, G.R. No. 157604, October 19, 2005, 473 SCRA 363 — Applied. Established that Rule 70, Section 21 does not divest appellate courts of power to issue preliminary injunctions to stay execution of RTC ejectment judgments when circumstances warrant.

• Republic v. Court of Appeals, G.R. No. 60169, March 23, 1990, 183 SCRA 620 — Applied. Held that despite the one-year period for reviewing decrees of registration, the State may still institute reversion when titles were secured through fraud; indefeasibility does not attach to void titles.

• Republic v. Guerrero, G.R. No. 133168, March 28, 2006, 485 SCRA 424 — Applied. Defined reversion as available "only in cases of fraudulent or unlawful inclusion of the land in patents or certificates of title."

• Spouses Morandarte v. Court of Appeals, 479 Phil. 870 (2004) — Applied. Recognized reversion for void titles resulting from mistake or oversight of government officials in including inalienable land (river portion) in a patent. The State is not estopped by its agents' errors.

• Heirs of Susana de Guzman Tuazon v. Court of Appeals, 465 Phil. 114 (2004) — Applied. Held that reconstitution does not pass upon ownership; a certificate of title is merely evidence of ownership, and any question on ownership must be threshed out in a separate suit.

• Amoroso v. Alegre, Jr., G.R. No. 142766, June 15, 2007, 524 SCRA 641 — Applied. Clarified that findings on ownership in reconstitution proceedings are mere obiter dictum.

• Article 476, Civil Code — Defines when an action for quieting of title may be brought: when there is a cloud on title by reason of any instrument, record, claim, or proceeding apparently valid but in truth invalid. Applied to hold that Vidal properly sought to quiet her title against Teofilo's adverse claim.

• Article 477, Civil Code — Requires the plaintiff in quieting of title to have legal or equitable title to the property. Applied to find that Vidal, as Doña Demetria's sole heir, had equitable title by succession.

• Article 1141, Civil Code — Provides that real actions over immovables prescribe in 30 years. Applied to hold that the quieting of title action, filed within 24 years of Doña Demetria's death, had not prescribed.

• Articles 1117, 1127, 1134, 1137, Civil Code — On acquisitive prescription. Applied to find Landtrade could not claim ordinary prescription (10 years) for lack of good faith, nor extraordinary prescription (30 years) because it possessed for only 2 years before suit.

• Article 172, Family Code — Allows proof of legitimate filiation by "any other means allowed by the Rules of Court" in the absence of record of birth or parental admission. Applied to sustain the probative value of Vidal's baptismal certificate.

• Rule 3, Section 11, Rules of Court — Provides that misjoinder or non-joinder of parties is not a ground for dismissal; parties may be added at any stage. Applied to reverse dismissal of expropriation complaint.

• Rule 67, Section 1, Rules of Court — Governs expropriation complaints; requires joining all persons owning, claiming to own, or occupying the property. Applied to hold MCFC a proper party and to permit expropriation even when title is in the Republic.

• Rule 70, Sections 19 and 21, Rules of Court — Section 19 provides for stay of execution of MTCC ejectment judgment pending RTC appeal by filing supersedeas bond and depositing rent. Section 21 makes RTC judgments immediately executory without stay provision. Applied to distinguish the two stages and hold the Section 19 issue moot; Section 21 held not to bar appellate injunction under Rule 58.

• Rule 63, Section 1, Rules of Court — Includes actions to quiet title among special proceedings for declaratory relief. Applied to distinguish quieting of title from ordinary civil actions where heirship declarations are impermissible.

• Section 101, Commonwealth Act No. 141 (Public Land Act) — Authorizes the Solicitor General to institute actions for reversion to the Government of lands of the public domain. Applied to hold the Republic's complaint validly instituted.

• Section 32, Presidential Decree No. 1529 (Property Registration Decree) — Provides one-year period for review of decree of registration on ground of fraud. Held not to bar the State's imprescriptible right to seek reversion of public land unlawfully included in certificates of title.

• Section 13, Republic Act No. 6395 (NAPOCOR Charter), as amended — Exempts NAPOCOR from taxes, duties, fees, and supersedeas bonds. Applied by the Court of Appeals (though the Supreme Court noted recent reversal of this exemption under A.M. No. 05-10-20-SC, without applying it retroactively to this case).

Chief Justice Renato C. Corona (Chairperson), Associate Justice Presbitero J. Velasco, Jr., Associate Justice Mariano C. Del Castillo, Associate Justice Jose Portugal Perez. No separate concurring opinions were noted.

No dissenting opinions were recorded. The decision was unanimous among the members of the First Division.