Facts:
The respondents were applying for a free patent to a certain parcel of land which they have been occupying, cultivating, planting, staying, and introducing improvements thereon and neither one of petitioners was in possession thereof. They had the land surveyed but the processing and approval of their application were held in abeyance despite the absence of any opposition on grounds that there allegedly existing certificates of title on said land in the name of Peltan Development. Peltan allegedly obtained their title from spouses Lorenzo Gana and Maria Carlos, however the respondents assail that the title was spurious and fictitious. Prior to their application for a free patent, the improvements they introduced to the land were bulldozed by one of the petitioners. They filed a complaint that by virtue of the spurious title produced by the petitioners and the illegal destruction of the respondent’s plants and dwellings, their rights for a free patent to the land were substantially prejudiced by petitioners and hold them liable to pay for actual and compensatory damages. Peltan filed a motion for preliminary hearing on affirmative defense on grounds that the respondents have no cause of action against them and they are not the real party of interest in the action they sought to assert as they have no subsisting title to present over the disputed property. Their contention was based on a former jurisprudence that the government thru the Solicitor General should be the real party of interest to file a motion for cancellation of the certificate of title. In answer, the respondents re-asserted their cause of action to their complaint and showed their rights, interest and claims to have been violated thereby placing them to a status of real party of interest.
The lower court dismissed the complaint ruling that the respondents were not a real party of interest. This decision was reversed by the court of appeals ruling that the lower court should have treated the action as accion publiciana to determine which party has the right to possession. The petitioners now file a petition for review and pray for the cancellation of the notation of lis pendens on their certificate of title.
Issues:
Whether or not the respondents are the real party of interest in their action against the petitioners?
Ruling:
The SC reversed the decision of the appellate court. It is a well-settled rule that the cause of action is determined by the allegations in the complaint and to resolve the motion to dismiss based on failure to state cause of action, only the facts in the complaint must be considered. The court held that the CA failed to appreciate the fact that the title of the petitioners were validly upheld by the court in a court proceeding (G.R. No. 109490 and in G.R. No. 112038). Every court should take mandatory judicial notice to court decisions when resolving motion to dismiss as required by Rule 129, section 1 of the Rules of Court. The CA erred in recognizing the rights of the respondents as one based on their actual possession of the land and their pending application for a free patent thereof. It also committed a reversible error to treat the issue as one of accion publiciana since the decision has already been rendered by the court before upholding the title of the petitioners as valid and genuine. Therefore, it is no longer an option to treat the case as one.
The respondents are held not as real party of interest since although they were not praying for the reversion of the land to the government such complaint would still result to the same under the Regalian doctrine. The respondents have no right over the land as they admit that neither they nor their predecessors owned the land which is construed that the land in dispute remains to be a property of public domain. If there is any person with real interest to the land it should be the government. The SC reversed and set aside the decision of the CA and cancelled the annotation of lis pendens to the petitioners’ title.
