MANILA, Philippines?Hundreds of thousands of landowners could be dispossessed of their lands with the Supreme Court ruling that nullified the land title of the family that claimed the Manotok Compound in Quezon City on Monday, according to four dissenting justices of the high court.
?The Court will be disquieting the titles held by generations of landowners since the passage in 1904 of Act. No. 1120 [Friar Lands Act]. Thousands, if not hundreds of thousands, of landowners could be dispossessed of their lands in these areas,? Associate Justice Antonio Carpio said in his dissenting opinion after the high court voted 9-4 to annul the land title held by the heirs of Severino Manotok IV.
The high court ruled on Monday that the Manotoks and two other groups of claimants to a large area covering 34.3 hectares failed to sufficiently prove their ownership of the area. It also declared null and void the documents presented by the claimants to prove their ownership and consequently declared that Lot 823 of what was known as the Piedad Estate in Quezon City legally belongs to the national government.
QC fire
The disputed area is in Culiat, Capitol Hills, Old Balara, and Ayala Heights that are now part of Quezon City. The controversy arose from conflicting claims to the area following the 1988 fire that gutted the Quezon City Hall and destroyed the records of the Register of Deeds.
The case was one of the many land disputes that ensued after the fire, but the Lot 823 case was the most contentious, the high court said.
The Piedad Estate was one of the 23 friar estates that the government bought from the Catholic religious orders in the beginning of the 20th century. The 23 friar estates covered 160,535.8 hectares of land in the provinces of Bulacan, Bataan, Cebu, Cavite, Isabela, Laguna, Mindoro, Rizal and Metro Manila.
Carpio said the majority of the court erred in citing technicalities that had already been superseded by subsequent administrative rulings and that the court unfairly nullified the title of a landowner after he had sufficiently proven the chain of titles on which he bases his claim of ownership.
Dissenting justices
Carpio?s dissenting opinion was supported by Associate Justices Presbitero Velasco and Arturo Biron. Justice Maria Lourdes Sereno echoed Carpio?s views in a separate dissenting opinion and stressed that ?the function of the courts...is to issue judicial edicts that consistently uphold legitimate expectations to promote stability and not chaos.?
Sereno said the high court?s ruling, penned by Associate Justice Martin Villarama, ?left open to attack the established legal principles on sales and perfection of contracts.?
Sereno said the majority opinion ?has not succeeded in clarifying the legal regime on friar lands but has instead created dangers for the system of property rights in the Philippines.?
Trumping the system
Sereno said the majority decision was based on a technical requirement that ?trumps? the entire system of acquiring the friar lands although other elements of possession and ownership have been satisfied.
?It enabled forgers of documents to land to take advantage of the antiquity of a land system, or the fact that the land system had endured massive destruction of its records due to fire, to attack land titles made vulnerable by these circumstances,? Sereno added.
The Court ruled that neither the Manotok clan nor the heirs of Homer Barque own Lot 823.
The court, in its 97-page decision, nullified Transfer Certificate Titles in the names of Severino Manotok IV and Homer L. Barque, and Deed of Conveyance issued to a certain Felicitas B. Manahan.
The Villarama decision was concurred in by Chief Justice Renato C. Corona and Associate Justices Teresita Leonardo de Castro, Diosdado M. Peralta, Lucas P. Bersamin, Mariano C. del Castillo, Roberto A. Abad, Jose P. Perez and Jose C. Mendoza. Associate Justice Conchita Carpio Morales wrote a concurring and dissenting opinion and Associate Justice Antonio Eduardo B. Nachura took no part.
