Republic v. Court of Appeals
REITERATIONFacts
The Antecedents: Matias Bustamante filed an application for land registration of approximately 880,000 square meters. Oppositions were filed by the Director of Forestry, Director of Fisheries, Isidro Bustria, and Julian Bustria. The Court of Appeals, on appeal, declared 783,275 square meters as accretion belonging to the State, modifying the lower court's decision. This was affirmed by the Supreme Court. The subject lot, Lot No. 7764, forms part of this area declared as public domain and classified for fishpond development. This lot was leased by the Republic of the Philippines to Porfirio Morado. Procedural History: Zenaida Bustria (daughter of Isidro Bustria) filed a complaint for ownership and possession of the subject lot against Porfirio Morado, without impleading the Republic. Due to Morado's failure to appear, he was declared in default, and the RTC rendered a decision declaring Zenaida Bustria as the absolute owner. Morado's Petition for Relief was denied, and his subsequent Petition for Certiorari with Preliminary Injunction was also denied by the Court of Appeals. The Petition: The Republic of the Philippines, invoking BP Blg. 129, filed a petition for annulment of the RTC decision, arguing that the land is public domain and under the jurisdiction of BFAR. The Court of Appeals dismissed the Republic's petition, holding that the Republic was not a real party-in-interest as it was not a party to the original case. Hence, the present petition for review.
Issue(s)
Whether the Republic of the Philippines has the personality to file an action for annulment of judgment when it was not a party to the original case. Whether the Regional Trial Court had jurisdiction to declare the land in question, which is part of the public domain classified for fishpond development, as private property.
Ruling
The petition is GRANTED. The decision of the Court of Appeals is REVERSED AND SET ASIDE. The decision of the Regional Trial Court is declared NULL AND VOID.
Ratio Decidendi
On the issue of personality to file an action for annulment of judgment: The appellate court erred in ruling that the Republic lacked personality to file the action. While an action to recover land is in personam, a party claiming ownership of a parcel of land that is the subject of a judgment has sufficient interest to bring an action for annulment, even if not a party to the original proceedings, provided they can prove the judgment was obtained through fraud and would be adversely affected. The State, as the owner of public land, is clearly adversely affected by a judgment that erroneously declares private ownership over its domain. The Republic can institute the proper action to assert its claim without necessarily seeking annulment if the judgment adversely affects its proprietary rights. On the issue of jurisdiction over public land: The Regional Trial Court acted without jurisdiction in declaring the subject lot, which is part of the public domain classified for fishpond development, as private property. Lands declared for fishery purposes are not alienable, and their possession, no matter how long, cannot ripen into ownership. The disposition of such lands falls under the jurisdiction of the Bureau of Fisheries and Aquatic Resources (BFAR) under PD 704. By applying for a fishpond permit with BFAR, Isidro Bustria, the predecessor-in-interest of private respondents, admitted the character of the land as suitable for fishpond development. Consequently, the trial court's decision is null and void as it disposed of inalienable public land.
Main Doctrine
A trial court has no jurisdiction to dispose of inalienable public land, and a decision declaring private ownership over such land is null and void. The State, even if not a party to the original case, has sufficient interest to seek annulment of a judgment that adversely affects its claim over public domain lands.