Balmaceda v. Bases Conversion and Development Authority
REITERATIONFacts
The Antecedents: Petitioners, represented by their attorney-in-fact Jacobina T. Alcantara, filed a complaint for forcible entry and damages against the Bases Conversion and Development Authority (BCDA), its then President Arnel Paciano D. Casanova, and City Engineer Marcelo M. Serpa Juan. Petitioners claimed to be legitimate occupants of Lot 3-A and Lot 3-B for over thirty years with the consent of Agustina Huerva Alfabeto, Jacobina's grandmother, who allegedly transferred her rights to Jacobina. They asserted that in April 2012, respondents forcibly entered the property by sending notices to vacate, demolishing structures, bulldozing roads, and fencing portions, thereby preventing petitioners from accessing their occupied areas. Procedural History: The Metropolitan Trial Court (MeTC) dismissed the complaint for lack of merit, finding that petitioners' title traced its roots from OCT No. 291, which was already cancelled and the land conveyed to the Republic of the Philippines and subsequently to the BCDA. The MeTC ruled that BCDA, as the registered owner, was entitled to possession and that respondents did not forcibly enter as they were authorized to evict under RA 7279. The Regional Trial Court (RTC) affirmed the MeTC Decision. The Court of Appeals (CA) also affirmed the RTC Decision, holding that BCDA's title was superior as the sale to Agustina was subsequent to the declaration of the property as a military reservation under PD 423, rendering the sale void. The CA further stated that petitioners could not claim ignorance of the property's status as a military reservation and that BCDA had the authority to enter and demolish structures without a court order under RA 7279. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners filed a Petition for Review assailing the CA's Decision and Resolution, arguing that the CA erred in affirming the lower courts' dismissal of their case.
Issue(s)
Whether the Court of Appeals correctly affirmed the ruling of the Regional Trial Court which sustained the Metropolitan Trial Court Decision dismissing the case. Whether petitioners' claim of ownership and possession over the subject property is valid; and whether BCDA, as the owner of the subject property, is entitled to possess it and to evict petitioners.
Ruling
The petition is bereft of merit. The Supreme Court affirmed the Decision dated October 11, 2017, and the Resolution dated March 27, 2018, of the Court of Appeals in CA-G.R. SP No. 140092, upholding the dismissal of the case for forcible entry and damages.
Ratio Decidendi
On the issue of whether the CA correctly affirmed the ruling of the RTC that sustained the MeTC Decision dismissing the case: The Supreme Court held that the issue of who between the parties is entitled to the material possession of the subject property involves factual matters beyond the ambit of a petition for review on certiorari. The Court is not a trier of facts, and questions of law are only permissible in a Rule 45 petition, with no exceptions applicable here. The findings of fact of the trial courts, especially when affirmed by the CA, are conclusive and binding upon the Supreme Court. Therefore, there was no cogent reason to disturb the uniform rulings of the MeTC, RTC, and CA in dismissing the case for lack of merit. On the validity of petitioners' claim of ownership and possession, and BCDA's entitlement to possession and eviction: The Supreme Court underscored that OCT No. 291, from which petitioners' title (TCT No. 340178) originated, had been conveyed to the United States and subsequently ceded to the Republic of the Philippines, leading to its cancellation. The Court took judicial notice that the land covered by OCT No. 291 is government property, as evidenced by proclamations and prior court decisions. Furthermore, jurisprudence dictates that a military reservation cannot be registered or be a subject of private disposition unless declared alienable and disposable. The subject property, being a portion of Parcel 3 PSU-2031 within the Fort Andres Bonifacio Military Reservation (FBMR), remains reserved for military purposes and cannot be privately appropriated. Consequently, the purported sale of the property from Ricardo to Agustina was void because it involved government property. As petitioners anchored their supposed right to possess the property on Agustina's void title, their claim was dismissed. The Supreme Court affirmed that the BCDA, as the owner of the subject property, is entitled to possess it and to evict petitioners. This right to possession is a direct consequence and attribute of ownership, as confirmed in previous rulings where the Court affirmed BCDA's ownership over the FBMR under RA 7227. The BCDA has the mandate to administer the FBMR, which includes the right to take possession. Moreover, pursuant to Section 28(b) of RA 7279, the BCDA is permitted to extrajudicially cause the eviction of petitioners and the demolition of structures on the property, as these actions are necessary for the implementation of government infrastructure projects. The Court also noted with approval that the BCDA provided prior notice and offered relocation and financial aid, despite not being legally required to do so, demonstrating no procedural or substantive shortcomings in its actions.
Main Doctrine
A title derived from a cancelled Original Certificate of Title (OCT) covering government property, particularly a military reservation, is void and cannot be the basis for a claim of ownership or possession. The Bases Conversion and Development Authority (BCDA), as the lawful owner of such property, is entitled to possession and may extrajudicially evict occupants under Republic Act No. 7279.