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Republic v. Datuin Case Digest

In the case of Republic v. Datuin, the Republic of the Philippines sought to cancel land titles it claimed were fraudulently issued, but the trial court granted summary judgment in favor of the respondents. The Court of Appeals incorrectly dismissed the Republic's petition for certiorari, finding that the trial court had committed grave abuse of discretion by deeming the Republic to have admitted material facts without proper evidence. Consequently, the Supreme Court nullified the trial court's orders and emphasized that genuine issues of fact must be resolved through trial, not summary judgment.

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38 views

Republic v. Datuin Case Digest

In the case of Republic v. Datuin, the Republic of the Philippines sought to cancel land titles it claimed were fraudulently issued, but the trial court granted summary judgment in favor of the respondents. The Court of Appeals incorrectly dismissed the Republic's petition for certiorari, finding that the trial court had committed grave abuse of discretion by deeming the Republic to have admitted material facts without proper evidence. Consequently, the Supreme Court nullified the trial court's orders and emphasized that genuine issues of fact must be resolved through trial, not summary judgment.

Uploaded by

anna liza lastimosa
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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TITLE: Republic v.

Datuin

GR NO. 224076

DATE: July 28, 2020

SUBJECT Special Civil Action of Certiorari; Summary Judgment


MATTER:

DOCTRINES: 1. The petition shall be accompanied by a certified true copy of the


judgment, order or resolution subject thereof, copies of all
pleadings and documents relevant and pertinent thereto, and a
sworn certification of non-forum shopping as provided in the
paragraph of Section 3, Rule 46.To justify its availment of Rule
65, the Republic cited the trial court's violation of its right to due
process amounting to grave abuse of discretion or excess of
jurisdiction.
2. In several cases, the Court sustained as proper remedy a
petition for certiorari where it was shown that the aggrieved
party's right to due process was violated and the trial court was
deemed to have been ousted of jurisdiction over the case.
3. A genuine issue means an issue of fact which calls for
presentation of evidence as distinguished from an issue which is
sham, fictitious, contrived, set up in bad faith, and patently
unsubstantial so as not to constitute a genuine issue for trial.

FACTS: The Republic of the Philippines filed a complaint for cancellation and
reversion of lan titles against Susan Datuin, Evelyn Dayot and several
realty corporations. The Republic claimed the lots were alienable public
land fraudulently titled to private parties. The respondents argued the
lots had been classified as alienable and disposable since 1969. The
trial court granted summary judgment dismissing the Republic’s
complaint. The CA dismissed the Republic’s petition for certiorari
challenging the summary judgment.

ISSUE/S: 1. Did the Court of Appeals correctly dismiss the petition for
certiorari for being allegedly an improper remedy against the trial
court's summary judgment in respondents' favor?
2. Did the trial court correctly deem the Republic to have admitted
the matters raised in respondents' request for admission and
based thereon, render a summary judgement against it?

RULING: 1. The Court of Appeals committed reversible error when it


dismissed the Republic's petition for certiorari in CA-G.R.
SP No. 134394 for improper remedy against the trial court’s
summary judgment in respondents’ favor.

Here, the trial court deemed the Republic to have admitted all the
affirmative defenses pleaded by respondents in their answer, including
the genuineness and due execution of the very documents subject of the
parties' conflicting claims, granted respondents' motion for summary
judgment based thereon, and rendered the summary judgment itself
altogether in its Order dated September 3, 2013 which it subsequently
affirmed under Order dated December 18, 2013. As will be shown in the
succeeding discussion, the trial court committed grave abuse of
discretion, amounting to excess or lack of jurisdiction when it rendered
its assailed dispositions.

2. the trial court, thus, gravely abused its discretion when it


issued its: (a) Order dated September 3, 2013 in Civil Case
No. 4929, ordaining that as a result of the Republic's failure
to respond to the Request for Admission, it was deemed to
have impliedly admitted the material facts as well as the
genuineness and due execution of several documents
subject of the Request for Admission, granting respondents'
motion for summary judgment based on these alleged
admissions, and rendering summary judgment against the
Republic; and (b) denying the Republic's subsequent motion
for reconsideration. Consequently, the aforesaid orders are
nullified.

Here, the trial court deemed the Republic to have admitted all the
affirmative defenses pleaded by respondents in their answer, including
the genuineness and due execution of the very documents subject of the
parties' conflicting claims, granted respondents' motion for summary
judgment based thereon, and rendered the summary judgment itself
altogether in its Order dated September 3, 2013 which it subsequently
affirmed under Order dated December 18, 2013. As will be shown in the
succeeding discussion, the trial court committed grave abuse of
discretion, amounting to excess or lack of jurisdiction when it rendered
its assailed dispositions.

First. Rule 26 of the Revised Rules of Court governs requests for


admission, thus:
SECTION 1. Request for Admission.— At any time after issues have
been joined, a party may file and serve upon any other party a written
request for the admission by the latter of the genuineness of any
material and relevant document described in and exhibited with the
request or of the truth of any material and relevant matter of fact set
forth in the request. Copies of the documents shall be delivered with the
request unless copies have already been furnished.

SECTION 2. Implied Admission.— Each of the matters of which an


admission is requested shall be deemed admitted unless, within a period
designated in the request, which shall not be less than fifteen (15) days
after service thereof, or within such further time as the court may allow
on motion, the party to whom the request is directed files and serves
upon the party requesting the admission a sworn statement either
denying specifically the matters of which an admission is requested or
setting forth in detail the reasons why he cannot truthfully either admit or
deny those matters, xxxA request for admission seeks to obtain
admissions from the adverse party regarding the genuineness of
relevant documents or relevant matters to enable a party to discover the
evidence of the adverse side and facilitate an amicable settlement of the
case to expedite the trial of the same. The key word is to expedite
proceedings, hence, it should seek to clarify vague allegations of the
opposing party and should not be a mere reiteration of allegations in the
pleadings.

Here, respondents' Request for Admission refers to material facts


already pleaded as defenses in their Answer. In fact, the allegations in
the Request for Admission and the Answer, except for a few innocuous
words are identical

Second. Summary judgment is embraced under Rule 35 of the 1997


Rules of Civil Procedure, viz.:
SECTION 1. Summary Judgment for claimant. - A party seeking to
recover upon a claim, counterclaim, or cross-claim or to obtain a
declaratory relief may, at any time after the pleading in answer thereto
has been served, move with supporting affidavits, depositions or
admissions for a summary judgment in his favor upon all or any part
thereof.

SECTION 2. Summary judgment for defending party. — A party against


whom a claim, counterclaim, or cross-claim is asserted or a declaratory
relief is sought may, at any time, move with supporting affidavits,
depositions or admissions for a summary judgment in his favor as to all
or any part thereof.

SECTION 3. Motion and proceedings thereon. — The motion shall be


served at least ten (10) days before the time specified for the hearing.
The adverse party may serve opposing affidavits, depositions, or
admissions at least three (3) days before the hearing. After the hearing,
the judgment sought shall be rendered forthwith if the pleadings,
supporting affidavits, depositions, and admissions on file, show that,
except as to the amount of damages, there is no genuine issue as to
any material fact and that the moving party is entitled to a judgment as a
matter of law.Summary judgment may be validly rendered when these
twin elements are present: (a) there must be no genuine issue as to any
material fact, except for the amount of damages; and (b) the party
presenting the motion for summary judgment must be entitled to a
judgment as a matter of law.

In the complaint, the Republic claimed that the subject lots are
"inalienable" and OCTs P-921 to P-926 and derivative titles were
fraudulently issued thereon. Respondents, on the other hand, countered
that the lots had already been classified as "alienable" as early as May
14, 1969, thus, OCTs P-921 to P-926 and its subsequent TCTs were
validly issued.
Undoubtedly, these are genuine issues pertaining to the actual
classification of the lots in question and the consequent validity or
invalidity of the titles issued thereon.

These genuine issues subsist and have not ceased to be. Hence, the
trial court gravely abused its discretion amounting to excess or lack of
jurisdiction when it deemed the same to be no longer existing based on
its erroneous conclusion that the Republic had impliedly admitted the
material facts to which they related.

The Court has time and again pronounced that where the facts pleaded
by the parties are disputed or contested, the proceedings for a summary
judgment cannot take the place of a trial.

Third. Under its Order dated September 3, 2013 the trial court
altogether, in one sweeping stroke, granted respondents' motion for
reconsideration dated July 16, 2013, granted their motion for summary
judgment dated February 26, 2013, and rendered the summary
judgment itself in respondents' favor. In so doing, the trial court deprived
petitioner of the opportunity before judgment was rendered, to first seek
a reconsideration of the grant of respondent's motion for reconsideration
and the grant of respondent's motion for summary judgment. This is
grave abuse of discretion, amounting to excess or lack of jurisdiction.

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