OPOSA VS FACTORAN

GR NO. 101083; JULY 30 1993

FACTS:
A taxpayers class suit was filed by minors Juan Antonio Oposa, et al.,
representing their generation and generations yet unborn, and represented by their
parents against Fulgencio Factoran Jr., Secretary of DENR. They prayed that
judgment be rendered ordering the defendant, his agents, representatives and
other persons acting in his behalf to:
1.
Cancel all existing Timber Licensing Agreements (TLA) in the country;
2.
Cease and desist from receiving, accepting, processing, renewing, or
appraising new TLAs;
and granting the plaintiffs such other reliefs just and equitable under the
premises. They alleged that they have a clear and constitutional right to a
balanced and healthful ecology and are entitled to protection by the State in its
capacity as parens patriae. Furthermore, they claim that the act of the defendant in
allowing TLA holders to cut and deforest the remaining forests constitutes a
misappropriation and/or impairment of the natural resources property he holds in
trust for the benefit of the plaintiff minors and succeeding generations.
ISSUE:
Do the petitioner-minors have a cause of action in filing a class suit to prevent the
misappropriation or impairment of Philippine rainforests?
HELD:
Yes. Petitioner-minors assert that they represent their generation as well as
generations to come. The Supreme Court ruled that they can, for themselves, for
others of their generation, and for the succeeding generation, file a class suit. Their
personality to sue in behalf of succeeding generations is based on the concept of
intergenerational responsibility insofar as the right to a balanced and healthful
ecology is concerned. Such a right considers the rhythm and harmony of nature
which indispensably include, inter alia, the judicious disposition, utilization,
management, renewal and conservation of the countrys forest, mineral, land,
waters, fisheries, wildlife, offshore areas and other natural resources to the end that
their exploration, development, and utilization be equitably accessible to the
present as well as the future generations.
Needless to say, every generation has a responsibility to the next to preserve that
rhythm and harmony for the full enjoyment of a balanced and healthful ecology. Put
a little differently, the minors assertion of their right to a sound environment
constitutes at the same time, the performance of their obligation to ensure the
protection of that right for the generations to come.

MANOTOK vs. BARQUE

G.R. Nos. 162335 & 162605; August 24, 2010
FACTS:

Piedad Estate originally owned by Philippine Sugar Estates Development

Company, Ltd., La Sociedad Agricola de Ultramar, the British-Manila Estate
Company, Ltd., and the Recoleto Order of the Philippine Islands. (It is a Friar Land.)
Piedad Estate was acquired by the Philippine Government pursuant to the Friar
Lands Act. The certificate of title in the name of the government was OCT No. 614.
The Estate was placed under the administration of the Director of Lands.

Controversy arising from conflicting claims over Lot 823 began after a fire
gutted portions of the Quezon City Hall on June 11, 1988 which destroyed records
stored in the Office of the Register of Deeds. Manotoks filed a petition with the LRA
for administrative reconstitution of TCT No. 372302 covering Lot No. 823 with an
area of 342,945 square meters GRANTED TCT No. RT-22481 (372302) was issued in
1991. In 1996, 8 years after the fire the Barques filed a petition with the LRA for
administrative reconstitution of TCT No. 210177 in the name of Homer Barque also
covering Lot 823. In support of their petition, the Barques submitted copies of the
alleged owners duplicate of the TCT, real estate tax receipts, tax declarations and a
Plan Fls 3168-D covering the property. MANOTOKs opposed alleging that TCT No.
210177 was spurious.
LRA found that the reconstitution of the Manotok title was fraudulent. Hence,
it ordered the Barque title to be reconstituted. BUT cancellation must 1 st be sought
in a court of competent jurisdiction of the 1991 Manotok TCT.
In the CA, Felicitas Manahan filed a motion to intervene and sought the
dismissal of the cases claiming ownership of the subject property.
On September 7, 2006, Felicitas Manahan and Rosendo Manahan filed a
motion to intervene, to which was attached their petition in intervention. They
alleged that their predecessor-in-interest, Valentin Manahan, was issued Sale
Certificate No. 511 covering Lot No. 823 and attached the findings of the NBI that
the documents of the Manotoks were not as old as they were purported to be.
Consequently, the Director of the Legal Division of the LMB recommended to the
Director of the LMB the reconstituted Manotok Title should be reverted to the state.
CAs findings that none of the parties were able to prove a valid alienation of
Lot 823 from the government in accordance with the provisions of Act No. 1120
otherwise known as the Friar Lands Act. Notably lacking in the deed of
conveyance of the Manotoks is the approval of the Secretary of Agriculture and
Commerce as required by Section 18 of the said law. Upon close scrutiny, the
factual allegations and voluminous documentary exhibits relating to the purchase of
Lot 823 by the predecessors-in-interest of the claimants revealed badges of fraud
and irregularity.

ISSUE: Who has the better right over Lot No. 823?
HELD: NO ONE! It belongs to the National Government.
Manotoks could not have acquired ownership of the subject lot as they had
no valid certificate of sale issued to them by the Government because their
Certificate lacks the signature of the Director of Lands and the Secretary of
Agriculture and Natural Resources
The decades-long occupation by the Manotoks of Lot 823, their payment of
real property taxes and construction of buildings, are of no moment. It must be
noted that the Manotoks miserably failed to prove the existence of the title
allegedly issued in the name of Severino Mantotok after the latter had paid in full
the purchase price. The Manotoks did not offer any explanation as to why the only
copy of TCT No. 22813 was torn in half and no record of documents leading to its
issuance can be found in the registry of deeds. As to the certification issued by the
Register of Deeds of Caloocan, it simply described the copy presented as
DILAPIDATED without stating if the original copy of TCT No. 22813 actually existed
in their records, nor any information on the year of issuance and name of registered
owner.
With regards to the claims of MANAHANS, copy of the alleged Sale Certificate
No. 511 can be found in the records of the DENR-NCR, LMB or National Archives.
Although the OSG submitted a certified copy of Assignment of Sale Certificate No.
511 allegedly executed by Valentin Manahan in favor of Hilaria de Guzman, there is
no competent evidence to show that the claimant Valentin Manahan or his
successors-in-interest actually occupied Lot 823, declared the land for tax purposes,
or paid the taxes due thereon.
Even assuming the existence and validity of the alleged Sale Certificate No.
511 and Assignment of Sale Certificate No. 511 presented by the Manahans, the CA
correctly observed that the claim had become stale after the lapse of 86 years from
the date of its alleged issuance. Citing Liao v. CA the certificates of sale x x x
became stale after 10 years from its issuance and hence cannot be the source
documents for issuance of title more than 70 years later.