Heirs of Reyes v. Director of Lands
REITERATIONFacts
The Antecedents: This case concerns a land registration dispute initiated by Domingo Reyes, who applied for the registration of eight parcels of land in Quezon. The Director of Lands and the Director of Forestry, along with private individuals, opposed the application. The core of the dispute involved whether a portion of the land sought to be registered fell within a forest classification, as asserted by the Director of Forestry, and the procedural validity of appeals concerning this matter. Procedural History: The initial application for land registration was filed before the Court of First Instance (CFI) of Quezon. The CFI adjudicated four parcels of land to Domingo Reyes in 1974. The Solicitor General, representing the Directors of Lands and Forestry, filed a notice of appeal and a motion for extension, which was contested by Domingo Reyes' counsel regarding timeliness. The CFI's subsequent orders regarding the appeals were complex, at one point dismissing the appeal for the Director of Forestry while giving due course to the Director of Lands, and later dismissing the Solicitor General's appeal entirely. This led to a petition for certiorari and mandamus before the Supreme Court (G.R. No. L-41968), which in 1995 set aside the dismissal of the appeal and directed the Solicitor General to file a proper petition for review with the Court of Appeals (CA). In compliance, the Solicitor General filed a Manifestation and Motion, which was later followed by a Motion for Execution by the Heirs of Domingo Reyes. The Regional Trial Court (RTC) in 2012 denied the motion for execution and granted the Solicitor General's motion, ordering the elevation of the records to the CA. The CA subsequently remanded the case to the RTC for reconstitution of missing exhibits, which proved unsuccessful. The Heirs of Domingo Reyes then withdrew their appeal before the CA, leading to an Entry of Judgment. The RTC subsequently denied the issuance of a certificate of finality, prompting the present petition. The Petition: The petitioners, the Heirs of Domingo Reyes, seek a review on certiorari of the RTC's Orders dated October 22, 2015, and March 18, 2016. These orders denied their motion for the issuance of a certificate of finality of judgment. The petitioners argue that the appeal filed by the Solicitor General, which was treated as a petition for review and subsequently withdrawn by the petitioners, should have led to a final and executory judgment in their favor. The core issue before the Supreme Court is whether the denial of the motion for a certificate of finality was proper, considering the convoluted procedural history and the conflicting actions of the parties and lower courts, particularly the effect of the withdrawal of the petitioners' appeal on the Solicitor General's petition for review.
Issue(s)
Whether the denial of the motion for issuance of a certificate of finality was proper. Whether the appeal filed by the Solicitor General was given due course.
Ruling
The Supreme Court denied the petition, affirmed the RTC's denial of the motion for issuance of a certificate of finality, and recalled the Entry of Judgment dated July 16, 2015, insofar as the appeal filed by the petitioners was concerned. The petition for review filed by the OSG was reinstated, and the CA was directed to proceed with the disposition of the case.
Ratio Decidendi
On the propriety of denying the motion for issuance of a certificate of finality: The Court reiterated that judgments or orders become final and executory by operation of law upon the lapse of the reglementary period for appeal without any appeal being perfected or any motion for reconsideration or new trial being filed. The determination of the period for filing an appeal is therefore crucial. In this case, the OSG's Manifestation and Motion, praying that its appeal be treated as a petition for review, was filed before the RTC. Although initially unacted upon, the RTC subsequently resolved this motion along with the petitioners' Motion for Execution. The RTC's Resolution explicitly stated that the appeal was considered as a petition for review and ordered the elevation of the records to the CA. This action by the RTC clearly indicates that the Solicitor General's appeal was given due course. Consequently, in view of the pendency of the Solicitor General's petition for review before the CA, the July 31, 1975 CFI Order had not yet attained finality. Therefore, the RTC correctly denied the petitioners' motion for the issuance of a certificate of finality, as there was no final and executory judgment to certify. On whether the appeal filed by the Solicitor General was given due course: The records show that after the Supreme Court's directive in G.R. No. L-41968, the OSG filed a Manifestation and Motion before the RTC, praying that its earlier appeal be treated as a petition for review and requesting the transmittal of the records to the CA. While this motion was pending, the petitioners filed a Motion for Execution. The RTC, in a Resolution dated May 22, 2012, resolved both motions. Crucially, the RTC's Resolution explicitly stated that the appeal was considered as a petition for review and ordered the elevation of the records to the CA for disposition. This action by the RTC unequivocally demonstrates that the Solicitor General's appeal was given due course. The subsequent withdrawal of the petitioners' appeal, which led to an Entry of Judgment, pertained specifically to their appeal on the denial of the motion for execution. The Court clarified that the termination of the case should extend only to the appeal filed by the petitioners concerning the denial of the motion for execution, and not to the petition for review filed by the Solicitor General. To avoid confusion and to bring order to the proceedings, the Court found it necessary to reinstate the petition for review filed by the OSG, necessitating the recall of the Entry of Judgment only insofar as the petitioners' withdrawn appeal was concerned.
Main Doctrine
Judgments or orders become final and executory by operation of law, not by judicial declaration. The finality of a judgment becomes a fact upon the lapse of the reglementary period of appeal if no appeal is perfected or no motion for reconsideration or new trial is filed. The determination of the period of filing an appeal is crucial.