Cabalum, Roman Augusto B.

2I - COL

Executive Summary

Barstowe Philippines Corporation v. Republic

GR No 133110; March 28 , 2007

Estoppel cannot run against the Republic except when there is an innocent purchaser for
value. This case involved the controversy as to who has the better right over the parcels of land.
The two conflicting parties are Barstowe Philippines Corp (BRC) and the Republic. BRC traced
its title from Servando Accibal (Servando). On the contrary, the Republic traced its title First
Philippine Holdings Corporation (FPHC). The Republic filed a petition for cancellation of title
against Antonio & Servando Accibal, and BPC. During the pendency of the civil case, there are
two intervenors. One intervenor is Gloria Accibal Rettoriano who alleged that BCP’s TCT was
obtained by Servando through fraud and gross bad faith. The other intervenor is EL-VI Realty
and Development Corporation (ERDC) who alleged that it acquired interest in the subject lots
after having entered into a Joint Venture Agreement with BPC, for the development of the
subject lots into a residential subdivision. ERDC alleged that the action initiated by the Republic
for the cancellation of the TCTs of BPC was already barred by laches and estoppel because of the
recognition accorded upon the said TCTs by the instrumentalities of the Republic, particularly
the Register of Deeds and the HLURB. The RTC rationalized that the title of BCP should prevail
because the title of the latter’s predecessor-in-interest was issued 5 or 6 years earlier than that of
the predecessor-in-interest of the Republic. However, the CA ruled in favor of the Republic. An
investigation conducted by the LRA revealed irregularities which raised serious doubts as to the
validity and authenticity of the certificate of titles of Servando.

The LRA Report, found the said certificates of titles spurious after a very detailed and exhaustive
analysis of the evidence available. Hence, this petition. Generally, estoppel cannot lie against the
State. An exception to that rule is when innocent purchasers for value are involved. Time-settled
is the doctrine that innocent third persons, relying on the correctness of the certificate of title,
acquire rights over the property, courts cannot disregard such rights and order the cancellation of
the certificate. Such cancellation would impair public confidence in the certificate of title, for
everyone dealing with property registered under the Torrens system would have to inquire in
every instance whether the title has been regularly issued or not.

In this case, the intervenor-buyers except for spouses Santiago are considered innocent
purchasers for value. Hence, their titles should be respected. In other words, the Republic cannot
recover from them. Moreover, BPC is not an innocent purchaser for value. Hence, BPC’s title
cannot prevail against the State. As a result, the unsold lands should be returned to the Republic.
Hence, as far as the subdivision lots still in the name of BPC are concerned, the Republic has the
option to either recover the said lots and demand that BPC demolish whatever improvements it
has made therein, to return the lots to their former condition, at the expense of BPC; or compel
BPC to pay the price of the land. The choice can only be made by the Republic, as the rightful
owner of the said subject lots.

Manotok v. Barque
GR No.162335,162605; December 18, 2008

On March 6, 2012, the Supreme Court en banc promulgated its resolution in Manotok vs.
Barque, G.R. Nos. 162335 & 162605, the case involving Lot No. 823 of the Piedad Estate (a
former friar land) located in Quezon City. Voting 9-6, the High Tribunal denied with finality the
motions for reconsideration filed by all parties in this case. It reiterated its August 24, 2012
decision declaring that the subject lot legally belongs to the national government of the Republic
of the Philippines, and denying the respective claims of the opposing parties (the Manotoks as
petitioners, the Barques as respondents, and the Manahans as intervenors) over Lot No. 823. 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 former’s
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 had 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. Thus, the Manotoks filed these petitions to
the SC.
The consolidated petitions were DENIED by the Supreme Court 1st Division, which
AFFIRMED the appealed CA resolutions. Justice Ynares-Santiago, wrote the opinion for the 1st
Division, reasoning that “the LRA properly ruled that the reconstituting officer should have
confined himself to the owner's duplicate certificate of title prior to the reconstitution. There is
no need to remand the case to the RTC for a re-determination on the validity of the titles of the
Barques and the Manotoks as the same has been squarely passed upon by the LRA and affirmed
by the appellate court. By opposing the petition for reconstitution and submitting their
administratively reconstituted title, petitioners acquiesced to the authority and jurisdiction of the
reconstituting officer, the LRA and the Court of Appeals, and recognized their authority to pass
judgment on their title. Manotoks could not have acquired ownership of the subject lot as they
had no valid certificate of sale issued to them by the Government because their Certificate lacks
the signature of the Director of Lands and the Secretary of Agriculture and Natural Resources
The decades-long occupation by the Manotoks of Lot 823, their payment of real property taxes
and construction of buildings, are of no moment. It must be noted that the Manotoks miserably
failed to prove the existence of the title allegedly issued in the name of Severino Manotok after
the latter had paid in full the purchase price. The Manotoks did not offer any explanation as to
why the only copy of TCT No. 22813 was torn in half and no record of documents leading to its
issuance can be found in the registry of deeds. As to the certification issued by the Register of
Deeds of Caloocan, it simply described the copy presented as “DILAPIDATED” without stating
if the original copy of TCT No. 22813 actually existed in their records, nor any information on
the year of issuance and name of registered owner.