Serapion v. Ambagan
REITERATIONFacts
The Antecedents: Rodolfo Serapion, Sr. and Rodolfo Serapion, Jr. (Rodolfo, et al.) filed an Amended Complaint for quieting of title and recovery of possession against Napoleon D. Ambagan and Philip Ambagan (Napoleon, et al.) over a parcel of land (Lot 15326). Rodolfo, et al. claimed ownership based on an Original Certificate of Title (OCT) No. M-4863 issued to Rodolfo, Sr., which was later donated to Rodolfo, Jr., and new titles were issued. They alleged Napoleon, et al. unlawfully occupied the lot. Napoleon, et al. countered that Rodolfo, Sr.'s free patent and OCT were void and fraudulent, claiming prior possession and application for a free patent. They also questioned Rodolfo, Sr.'s authority to file the complaint. Procedural History: The Municipal Trial Court (MTC) dismissed Rodolfo, et al.'s complaint, finding Rodolfo, Sr. not the real party-in-interest due to lack of proven authority to represent his son, Rodolfo, Jr. The MTC also found Rodolfo, Sr.'s application for free patent fraudulent and ordered the reversion of Lot 15326 to the public domain, partially granting Napoleon, et al.'s counterclaim but denying their prayer for reconveyance. The Regional Trial Court (RTC) affirmed the MTC ruling. The Court of Appeals (CA) denied Rodolfo, Sr.'s petition for review, agreeing that Rodolfo, Sr. was not the real party-in-interest and that Rodolfo, et al. failed to establish their claim. The CA referred the reversion of the property to the Office of the Solicitor General (OSG). The CA also ruled that Napoleon, et al. lacked standing to ask for the cancellation of Rodolfo, Sr.'s title and for reconveyance, as such an action should be brought by the State. The Petition: Both parties filed consolidated petitions for review on certiorari before the Supreme Court, assailing the CA's decision and resolution.
Issue(s)
Whether the Court of Appeals erred in declaring that Napoleon, et al. did not have standing to ask for the reconveyance of Lot 15326 and that reconveyance is the proper remedy. Whether the Court of Appeals erred in denying Rodolfo, et al.'s petition for review from the RTC ruling which affirmed the cancellation of the free patent and OCT issued in Rodolfo, Sr.'s name, and in referring the case to the OSG for the reversion of Lot 15326 in favor of the government. Whether Rodolfo, Sr. was the real party-in-interest and was authorized to file the Amended Complaint for quieting of title and recovery of possession.
Ruling
The petitions are denied. The Decision dated October 18, 2018 and the Resolution dated July 5, 2019 of the Court of Appeals in CA-G.R. SP No. 149380 are affirmed with modification, dismissing the counterclaim of Napoleon Ambagan and Philip Ambagan for the annulment of Free Patent No. (IV-1) 009894 and Original Certificate of Title No. M-4863 issued in the name of Rodolfo Serapion, Sr., without prejudice to the right of the State to file the appropriate action for reversion.
Ratio Decidendi
On the issue of Napoleon, et al.'s standing to file the reversion case and the nature of the counterclaim: The Court upheld the CA's ruling that Napoleon, et al. did not have standing to ask for the cancellation of Rodolfo, Sr.'s free patent and OCT and for the reconveyance of Lot 15326 because their counterclaim was in essence an action for reversion, which only the Solicitor General can bring. They failed to allege or prove prior ownership that would vest them with a pre-existing right, nor did they demonstrate possession in the character and for the period required by law to vest imperfect title. Their own free patent was also previously cancelled by the DENR without appeal. The proper procedure for reversion of public land is through an action filed by the Solicitor General. Therefore, Napoleon, et al.'s counterclaim was dismissed for failure to state a cause of action, without prejudice to the State's right to file an appropriate action for reversion. On the issue of the denial of Rodolfo, et al.'s petition for review and referral to the OSG: The Court agreed with the CA that the proper procedure for reversion of public land is through an action filed by the Solicitor General. The Court clarified that while the MTC and RTC found Rodolfo, Sr.'s application fraudulent, the proper procedure for reversion of public land is through an action filed by the Solicitor General. On the issue of Rodolfo, Sr.'s standing and authority to file the Amended Complaint: The Court affirmed the CA's ruling that Rodolfo, Sr. was not the real party-in-interest to file the Amended Complaint for quieting of title and recovery of possession. The property, Lot 15326, was already donated by Rodolfo, Sr. to his son, Rodolfo, Jr., and titled in the latter's name. Therefore, Rodolfo, Jr. was the real party-in-interest. Rodolfo, Sr. failed to present sufficient evidence to prove that Rodolfo, Jr. specifically authorized him to institute the action, as the Special Power of Attorney (SPA) presented was questionable, general in tenor, and executed five years prior to the filing of the case. Consequently, the Amended Complaint failed to state a cause of action for lack of a real party-in-interest and proper authorization.
Main Doctrine
A party not possessing legal or equitable title or interest in a property cannot maintain an action for quieting of title. Furthermore, an action for reversion of public land to the State can only be instituted by the Solicitor General, not by private individuals.