Republic vs. Samson-Tatad (C.J.
Sereno, 17 April 2013) Facts The Republic of the Philippines, through the Department of Public Works and Highways, filed a Complaint for the expropriation of several parcels of land against several defendants including the Genato Spouses, whose ownership over a parcel of land was evidenced by a TCT. While the expropriation proceedings were pending, the Republic received a letter from Engr. Gatan of the DPWH-NCR, stating that the property claimed by the Genato Spouses was government land and that the TCT was of dubious origin as it overlapped with government property. Consequently, the Republic filed an Amended Complaint to limit the coverage of the proceedings to an area conforming to the findings of Engr. Gatan. Furthermore, the Republic filed a Motion to declare the property as being subject to conflicting claims; the RTC granted this motion. While the Republic was presenting evidence to show that the property was owned by the State, the Genato spouses objected as the presentation of evidence would constitute a collateral attack on the validity of the TCT, which was barred by Sec 48 of PD 1529. The RTC ruled for the Genato Spouses and barred the Republic from presenting their evidence, ruling that Sec 48 of PD 1529 mandates that the validity of TCTs can only be raised in an action expressly instituted for that purpose. The CA affirmed the decision of the RTC Issue Whether or not the presentation of evidence in an expropriation proceeding to show that a parcel of land is actually owned by the State is barred by Sec 48 of PD 1529 for being a collateral attack Held No, the State may still present evidence Ratio The Court has previously ruled that the court which hears an expropriation case also has the jurisdiction to determine, in the same proceeding, the issue of ownership of the land, as evidenced by Sec 9 of Rule 69. The existence of doubt in the title of a person claiming ownership of the properties to be expropriated does not bar the commencement of an action or proceeding in the same court regarding the ownership of the property. The Rules of Court merely require that the Republic state in its complaint that the true ownership cannot be ascertained. However, the findings of ownership in an expropriation proceeding is not final and binding as the purpose of expropriation is for the taking of the property by the State and not to prove or disprove a right of possession. The determination of ownership is akin to that of ejectment cases, where the determination of ownership is still open to challenges through the proper actions. In any case, the action is not a collateral attack on a Torrens Title. The Court has explained that a direct action is one where the objective of the action is to nullify the title by annulling or setting aside the judgment that decreed the title, or to enjoin its enforcement. On the other hand, the attack is indirect or collateral, in an action to obtain a different relief, an attack on the judgment is nevertheless made as an incident thereof. Here, the amendment merely limited the coverage of the expropriation proceedings to the uncontested portion of the property. Meanwhile, the RTC Order declaring the property as subject to conflicting claims is a recognition that there are different claimants to the sums to be awarded as just compensation. There is no action being made to nullify the title, but simply a limited inquiry is being made on the propertys owner ship the contest regarding the title is merely incident to the issue of who deserves the compensation. Previously, the court has ruled that an Answer praying for cancellation of a Torrens title is a collateral attack. However, the resolution of ownership in a partition case was determined not be a direct or collateral attack as it would be premature to effect partition over disputed properties. The determination of ownership in an expropriation proceeding is analogous to the latter situation.
