In the Philippines, a municipality cannot seek the nullification of a land title based solely on a claim of territorial jurisdiction without asserting ownership over the land. The Supreme Court held that an action for nullification of title requires the claimant to prove prior ownership and demonstrate fraud or mistake in obtaining the title. This decision underscores the importance of establishing a clear ownership right before challenging the validity of a land title.

Land Dispute in Ifugao: Can a Municipality Nullify a Title Based on Territorial Claim Alone?

This case revolves around a land dispute between SN Aboitiz Power-Magat, Inc. (SNAP) and the Municipality of Alfonso Lista, Ifugao. The municipality sought to nullify Special Patent No. 3723 and Original Certificate of Title (OCT) No. 0-1, arguing that the National Power Corporation (NPC) fraudulently secured the patent by misrepresenting the location of the land. According to the municipality, the land was actually located within its territorial jurisdiction, depriving it of tax revenues. SNAP, as the successor-in-interest of NPC, argued that the municipality’s claim lacked a cause of action because it did not assert ownership over the land. The central legal question is whether a municipality can nullify a land title based solely on a claim of territorial jurisdiction, without asserting a right of ownership.

The Supreme Court addressed whether the Municipality of Alfonso Lista had successfully asserted a valid cause of action. The Court reiterated the essential elements required for an action to nullify a title, emphasizing the necessity of proving a pre-existing right of ownership. The Court cited established jurisprudence, stating:

In an action for nullification of title or declaration of its nullity, the complaint must contain the following allegations for the sufficiency of cause of action: (1) that the claimant is the owner of the subject land prior to the issuance of the title to the defendant; and (2) that fraud or mistake was perpetrated in obtaining said title over the subject land.

The Court found that the municipality’s claim was primarily based on its right of jurisdiction and the alleged deprivation of tax revenues, rather than a claim of ownership. The municipality argued that the fraudulent securing of the patent altered legally established provincial boundaries, thus depriving it of its territorial jurisdiction and tax revenues. The Court emphasized that without a claim of ownership, there was no right upon which the municipality could anchor its claim against SNAP. This lack of a cause of action justified the dismissal of the amended complaint.

Building on this principle, the Court also addressed the municipality’s alternative prayer for the amendment of the subject title to reflect the true location of the land. The Court referred to Section 108 of Presidential Decree No. 1529 (P.D. 1529), which governs the amendment and alteration of certificates of title. This section outlines specific instances in which a certificate of title may be amended, such as when registered interests have terminated or when there has been an error or omission in the certificate.

The Court highlighted that proceedings under Section 108 are summary in nature and are intended for resolving clerical errors or uncontroversial issues. If there is an adverse claim or serious objection from any party in interest, the case becomes controversial and must be resolved through an ordinary case. In this instance, the Court found that the issues raised by the municipality were indeed controversial and could not be summarily disposed of. The Court stated:

Such relief under said provision can only be granted if there is unanimity among the parties, or there is no adverse claim or serious objection on the part of any party in interest, otherwise the case becomes controversial and should be threshed out in an ordinary case or in the case where the incident properly belongs. The issues are limited to those which are so patently insubstantial as not to be genuine issues.

The Court pointed out that allowing the amendment of the title would essentially alter the territorial jurisdiction over the Province of Isabela, given the municipality’s claim that the land was within its territory. The Court also noted the existence of an unresolved territorial dispute between the Province of Isabela and the Province of Ifugao, which further complicated the matter. The Province of Ifugao impleaded the Province of Isabela when it filed the amended complaint, maintaining its argument that the location of the subject parcels of land are within its territorial jurisdiction. However, the latter failed to file its Answer. Thus, any relief granted in this action would preempt the proceedings which may later on take place with respect to the territorial jurisdiction of both provinces.

Consequently, the Court emphasized that the proper remedy for resolving boundary disputes between local government units is outlined in Section 118 of the Local Government Code, which mandates amicable settlement through the respective Sanggunians (local legislative bodies) of the provinces involved. Section 118(c) of the Local Government Code provides:

Boundary disputes involving municipalities or component cities of different provinces shall be jointly referred for settlement to the Sanggunians of the provinces concerned.

The Supreme Court concluded that the municipality’s territorial claim could not be resolved in an action for nullification of title or in an action to amend title. It emphasized that the proper venue for addressing the boundary dispute was through the mechanisms provided in the Local Government Code.

FAQs

What was the key issue in this case?	The key issue was whether a municipality could nullify a land title based solely on a claim of territorial jurisdiction, without asserting ownership over the land. The Supreme Court ruled that it could not.
What are the requirements for an action to nullify a land title?	To nullify a land title, the claimant must prove prior ownership of the land and demonstrate that fraud or mistake was involved in obtaining the title. These requirements are crucial for establishing a valid cause of action.
What is the proper procedure for resolving boundary disputes between local government units?	Boundary disputes between local government units should be resolved amicably through the respective Sanggunians (local legislative bodies) of the provinces involved, as outlined in Section 118 of the Local Government Code. This process ensures that disputes are addressed in a structured and equitable manner.
Can a certificate of title be amended?	Yes, a certificate of title can be amended under Section 108 of Presidential Decree No. 1529, but only in specific instances, such as when registered interests have terminated or when there has been an error or omission in the certificate. The amendment process is typically summary in nature and limited to uncontroversial issues.
What happens if there is a dispute regarding the amendment of a title?	If there is an adverse claim or serious objection from any party in interest, the case becomes controversial and must be resolved through an ordinary case rather than a summary proceeding. This ensures that all parties have an opportunity to present their arguments and evidence.
What was the alternative relief sought by the Municipality of Alfonso Lista?	The municipality alternatively sought to amend the subject title to reflect the true location of the land as Barangay Sto. Domingo, Alfonso Lista, Ifugao. This alternative relief was denied because the issues were controversial and could not be summarily disposed of.
Why was the municipality’s claim dismissed?	The municipality’s claim was dismissed because it did not assert ownership over the land and instead based its claim solely on territorial jurisdiction, which is insufficient to nullify a land title. Without a claim of ownership, there was no right upon which the municipality could anchor its claim against SNAP.
What is the significance of Section 118 of the Local Government Code in this case?	Section 118 of the Local Government Code provides the proper remedy for resolving boundary disputes between local government units, which is through amicable settlement via the respective Sanggunians of the provinces involved. This section underscores that the boundary dispute should not be resolved in an action for nullification of title.

This case clarifies the requirements for nullifying land titles and resolving boundary disputes in the Philippines. It underscores the importance of asserting ownership when challenging the validity of a land title and provides a clear framework for addressing territorial disputes through the mechanisms outlined in the Local Government Code.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SN Aboitiz Power-Magat, Inc. vs. The Municipality of Alfonso Lista, Ifugao, G.R. No. 198647, November 20, 2017