Figuracion v. Libi
REITERATIONFacts
The Antecedents: Galileo Figuracion owned Lot No. 899-D-2. The Cebu City government expropriated it in 1948 for N. Escario Street and paid ₱23,700.00. Later, the Sangguniang Panlungsod approved the reconveyance of an unused portion, Lot No. 899-D-2-A (subject lot), to Isagani Figuracion, Galileo's successor-in-interest. A deed of sale was executed for ₱40,000.00. Upon resurvey, the subject lot was found to be 130 sq. m. An amended deed of sale was executed for ₱65,000.00. TCT No. 113746 was issued to Isagani Figuracion. Respondents were found to be using the subject lot and refused to vacate. Procedural History: Petitioners, as successors-in-interest of Isagani Figuracion, filed an unlawful detainer case (Civil Case No. R-34287) which they won in the MTC, RTC, and CA. Subsequently, respondents filed a complaint for easement of right of way (Civil Case No. CEB-21193) against petitioners, later amended twice to implead Cebu City and shift the cause of action to annulment of resolutions, deed of sale, and TCT No. 122309, and for damages. The RTC declared the resolutions, deed of sale, and TCT No. 122309 null and void. Petitioners appealed to the CA, which affirmed the RTC decision. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners assail the CA decision, raising issues of res judicata, forum shopping, error in declaring the reconveyance documents void, lack of legal capacity to sue, prescription, and failure to award damages.
Issue(s)
Whether the complaint in Civil Case No. CEB-21193 is barred by res judicata or conclusiveness of judgment; and whether respondents are guilty of forum shopping. Whether the Court of Appeals erred in declaring the Sangguniang Panlungsod resolutions, deed of sale, amended deed of sale, and TCT No. 122309 null and void. Whether respondents have the legal capacity to sue. Whether the action is barred by laches and prescription. Whether damages should have been awarded to petitioners. Whether the reconveyance of the subject lot by Cebu City to petitioners was valid.
Ruling
The Supreme Court granted the petition, annulled and set aside the decisions of the CA and RTC, and dismissed the complaint in Civil Case No. CEB-21193. The Court found that respondents lacked the legal personality to file the action for annulment of title and reversion of public land.
Ratio Decidendi
On res judicata, forum shopping, and the legal standing of respondents: While the Court did not extensively discuss res judicata and forum shopping, its primary focus on the lack of legal standing of the respondents rendered these issues moot. The Court held that respondents were not the real parties in interest to institute Civil Case No. CEB-21193. The case, in essence, was for reversion of the subject lot to the public domain, as it was part of expropriated land for a public street. Reversion actions must be instituted by the Solicitor General in the name of the Republic of the Philippines. Respondents, who did not claim title or possession and had abandoned their claim for a right of way, had no material interest in the annulment of petitioners' title. Their interest was merely a future expectancy, not a present substantial interest required for legal standing. The Court cited VSC Commercial Enterprises, Inc. v. Court of Appeals to define real interest as a material interest, not a mere expectancy or a desire to vindicate the rights of a third party. The RTC acted without jurisdiction in entertaining the complaint filed by parties without legal personality. On the validity of the Sangguniang Panlungsod resolutions, deed of sale, amended deed of sale, and TCT No. 122309: The Court found that the reconveyance of the subject lot by Cebu City to petitioners was valid. The subject lot was part of expropriated land for N. Escario Street, but it was not utilized for that purpose. The Sangguniang Panlungsod, through Resolutions No. 330 and No. 2345, declared the lot vacant and available for conveyance, recognizing the right of the former owner's successor-in-interest to repurchase it. These resolutions, issued in the exercise of the city government's official functions, constituted clear evidence of the intention to reconvey the property. The Court distinguished this from cases where former owners failed to prove a right to repurchase. The Court also noted that the Revised Charter of Cebu City granted the City Council the power to close city roads and convey property withdrawn from public servitude. Therefore, the resolutions, deeds of sale, and TCT No. 122309 were validly issued. On the legal capacity of respondents to sue: The Court held that respondents were not the real parties in interest to institute Civil Case No. CEB-21193. The case, in essence, was for reversion of the subject lot to the public domain. Reversion actions must be instituted by the Solicitor General in the name of the Republic of the Philippines. Respondents, who did not claim title or possession and had abandoned their claim for a right of way, had no material interest in the annulment of petitioners' title. Their interest was merely a future expectancy, not a present substantial interest required for legal standing. The RTC acted without jurisdiction in entertaining the complaint filed by parties without legal personality. On prescription and laches: The Court's finding that the RTC acted without jurisdiction and that the respondents lacked legal standing rendered the issues of prescription and laches secondary. The fundamental flaw was the initial filing of the case by parties who had no right to do so, making the subsequent proceedings and the RTC's decision a nullity. The Court emphasized that a suit filed by a person who is not a party in interest must be dismissed, irrespective of the passage of time. On damages: The Court did not award damages to the petitioners as prayed for in their counterclaim. The dismissal of the complaint due to the respondents' lack of legal standing meant that the underlying action for annulment and reversion was invalid. Consequently, any claims for damages arising from that invalid action would also be dismissed. The focus of the Supreme Court was on rectifying the procedural defect of lacking a real party in interest, rather than adjudicating claims for damages. On the validity of the reconveyance: The Court found that the reconveyance of the subject lot by Cebu City to petitioners was valid. The subject lot was part of expropriated land for N. Escario Street, but it was not utilized for that purpose. The Sangguniang Panlungsod, through Resolutions No. 330 and No. 2345, declared the lot vacant and available for conveyance, recognizing the right of the former owner's successor-in-interest to repurchase it. These resolutions, issued in the exercise of the city government's official functions, constituted clear evidence of the intention to reconvey the property.
Main Doctrine
Respondents, not being the real parties in interest and lacking legal standing, cannot institute an action for annulment of title and reversion of public land. Their original cause of action for easement of right of way was abandoned when they amended their complaint.