Republic v. Reyes
REITERATIONFacts
The Antecedents: Private respondents, spouses Alexander V. Ruiz and Elizabeth E. Ruiz, and Evelyn M. Eugenio, applied for the registration of three parcels of land totaling 106.2887 hectares. The Director of Lands and the Director of Forestry, represented by the Provincial Fiscal of Bataan, opposed the application, alleging insufficient title, lack of actual possession, that the land is part of the public domain, failure to pay taxes, absence of prior cadastral proceedings, and non-compliance with Act 496. Procedural History: The Court of First Instance of Bataan, presided over by respondent Judge Amado B. Reyes, rendered a decision on March 14, 1972, ordering the registration of the lands in favor of the private respondents. A copy of the decision was served on the Provincial Fiscal on the same day, who mailed a copy to the Solicitor General. On April 15, 1972, the respondent Judge ordered the issuance of a decree, which was issued by the Commissioner of Land Registration on April 25, 1972. Original Certificate of Title No. N-225 was issued by the Register of Deeds of Bataan on April 28, 1972. Subsequently, the land was sold and reconveyed, and eventually sold to Farmers Fertilizer Corporation. The Petition: On September 25, 1972, the Republic of the Philippines, through the Solicitor General, filed a petition for review on certiorari, seeking to annul the decision of the trial court. The Solicitor General argued that the trial court lacked jurisdiction, the survey plan was inadmissible, the land was public domain, and the area exceeded the limit for free patents. Later, an amended petition was filed, and a motion for new trial was submitted, alleging fraud and collusion. The Solicitor General claimed he only learned of the decision on September 1, 1972, when he requested the records.
Issue(s)
Whether the service of the trial court's decision upon the Provincial Fiscal on March 14, 1972, constituted valid service upon the Solicitor General for the purpose of reckoning the reglementary period. Whether the petition for review on certiorari and the motion for new trial were filed within the reglementary period. Whether the finality of the land registration decree precludes the State from seeking the recovery of the land if it is indeed inalienable public domain.
Ruling
The petition for review on certiorari and the motion for new trial are dismissed. The Court held that the petition was filed out of time, and the decision of the trial court had become final and executory. The Court also found no evidence of fraud or collusion on the part of the respondent judge. However, the dismissal is without prejudice to any proper action for annulment of the decree of title, cancellation of certificates of title, and reversion of the land to the State, as well as appropriate proceedings against those whose neglect prejudiced the State.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the service of the decision upon the Provincial Fiscal was effective service upon the Solicitor General. Applying the principle of agency, the Court held that notice to an authorized agent is notice to the principal. The Solicitor General had expressly authorized the Provincial Fiscal to represent the office in the case and had maintained silence while the Fiscal performed all legal acts, including filing oppositions and motions. This 'silent acquiescence' confirmed the Fiscal's authority to act in all stages of the case. Thus, the OSG is deemed notified as of March 14, 1972, when the Fiscal received the copy. On Issue 2: The Court determined that both the petition for review and the motion for new trial were filed beyond the legal deadlines. A decision in land registration becomes final 30 days after the party receives notice. Since the OSG was deemed notified on March 14, 1972, the period to appeal or move for a new trial expired on April 14, 1972. The petition filed on September 25, 1972, was over five months late. Even a petition for relief under Rule 38, which requires filing within 60 days of learning of the judgment and no more than six months from entry, would have been untimely given the constructive notice via the agent. On Issue 3: The Court clarified that while it could not grant the specific relief requested in the late petition due to lack of jurisdiction, the State is not left without recourse. If the land is truly inalienable public domain or part of a military reservation (as alleged by the OSG regarding Proclamation No. 10), the State may institute a separate action for 'reversion.' The Court emphasized that a decree of registration obtained through fraud is valid but voidable, and the State's right to recover public land unduly registered is a separate cause of action that must be litigated with proper evidence regarding the identity of the land and the status of current owners.
Main Doctrine
A petition for review on certiorari filed beyond the reglementary period after a decision in a land registration case has become final and executory, and a decree and title have been issued, will be dismissed. Notice to the counsel of record, such as the Provincial Fiscal representing the Solicitor General, is considered notice to the principal, the Solicitor General.