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SEVERINO M. MANOTOK IV et al. v. HEIRS OF HOMER L. BARQUE, rep. by TERESITA BARQUE HERNANDEZ G.R. Nos.

162335 & 162605 March 6, 2012

FACTS: Covered by Lot 823, the Piedad estate is a friar land nestled in the barrios of Capitol Hills, Old Balara, Culiat and the posh Ayala Heights in Quezon City, with a market value pegged at P4 billion. Claiming ownership of the land were the heirs of Severino Manotok IV and those of Homer Barque and Felicitas Manahan. The Barques filed a petition for administrative reconstitution of TCT No. 210177 issued in the name of their predecessor, Homer L. Barque, which was allegedly destroyed in the fire that gutted the Quezon City Hall, including the Office of the Register of Deeds of Quezon City, sometime in 1988. The Manotoks filed their opposition to the Barques petition, claiming that the lot covered by the title sought to be reconstituted by the latter forms part of the land covered by the formers own reconstituted title, TCT No. RT-22481, and alleging that TCT No. 210177 in the name of Homer L. Barque is spurious. On June 30, 1997, the reconstituting officer denied the reconstitution of TCT No. 210177 on grounds that the two lots covered by the Barques title appear to duplicate the lot covered by the Manotoks own reconstituted title; and that the Barques plan, Fls -3168-D, is a spurious document. On appeal by the Barques, the LRA reversed the reconstituting officer and ordered that reconstitution of the Barques title be given due course, but only after the Manotoks own title has been cancelled upon order of a court of competent jurisdiction. The parties separately appealed to the CA. The two divisions of the CA where the cases landed similarly modified the LRA decision, ordering the Register of Deeds of Quezon City to cancel the Manotoks title without a direct proceeding with the RTC, and directing the LRA to reconstitute the Barques' title. ISSUE: Who is the real owner of the subject parcels of land? HELD: In a 32-page resolution penned by Associate Justice Martin Villarama Jr., the Court en banc junked the separate motions for reconsideration filed by claimants, putting an end to the 20 years of legal battle over the parcels of land.

The majority ruling upheld the recommendations made by the Court of Appeals (CA) that declared the Manotok's title as null and void, while the subject property is still part of the property of the government. On the other hand, the SC ruled that the Barque's claim of ownership was anchored on fake and spurious documents. The CA earlier said that none of the parties were able to prove a valid acquisition of Lot 823 of the Piedad estate from the government in accordance with the provisions of Act 1120, or the "Friar Lands Act." Due to the "serious flaws" in the title produced by Severino Manotok that were brought to light during the reconstitution proceedings, the CA deemed it proper to give all the parties full opportunity to present more evidence, and in particular, for the Manotoks to prove their presumed just title over the property, which is also claimed by the Barques and the Manahans. "As it turned out, none of the parties were able to establish by clear and convincing evidence a valid alienation from the government of the subject friar land. The declaration of ownership in favor of the government was but the logical consequence of such finding," the SC ruled. The High Court further noted that the Manotoks failed to prove the existence of sale certificate in the records of the Department of Environment and Natural Resources-Land Management Bureau (DENR LMB). Likewise, the SC noted that the approval of the then Secretary of Agriculture and Commerce as required by Section 18 of the Act 112 is lacking in the deed of conveyances of the Manotoks. This provision states that: "No lease or sale made by the Chief of the Bureau of Public Lands under the provisions of this Act shall be valid until approved by the Secretary of the Interior." "We, thus held that no legal right over the subject friar land can be recognized in favor of the Manotoks... in the absence of the certificate of sale duly signed by the Director of Lands and approved by the Secretary of Agriculture and Natural Resources," the Court ruled. Notes: Summary of the rulings made by the Supreme Court since the inception of this case: (1) Part I The December 12, 2005 decision of the 1st Division (4-1 vote, Ynares-Santiago, J., ponente), which denied the Manotoks consolidated petitions and sustained the order for the cancellation of the Manotoks title and for the reconstitution of the Barques title; (2) Part II The December 18, 2008 en banc resolution (8-6-1 vote, Tinga, J., ponente), which reversed the decision of the 1st Division and remanded the petitions to the CA for further proceedings; (3) Part III The August 24, 2010 en banc decision (9-5-1 vote, Villarama, J., ponente), which denied the Manotoks consolidated petitions and declared their title null and void, but also denied the petition for reconstitution of the Barques and declared that the subject lot legally belongs to the national government of the Republic of the Philippines; (4) Part IV The March 6, 2012 en banc resolution (9-6 vote, Villarama, J., ponente) denying with finality the motions for reconsideration of the parties.

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