National Spiritual Assembly of the Bahais v.

Pascual
G.R. No. 169272
July 11, 2012
Justice Brion
National
Spiritual
Assembly
of
the
Bahais
of the Philippines
petitioners
responden Alfredo Pascual (Regional Executive Director of DENR)

chas

ts
summary Petitioner filed a complaint for quieting of title against respondents. It argued

that it is the absolute owner of the land and had been in continuous possession
for 30 years, and that a cloud over the title existed because of an invalid
decision by the Bureau of Lands ordering them to vacate the lot. On the other
hand, respondent argued that such decision of the Bureau had already become
final and executor and that the complaint must be dismissed for failure to state
a cause of action.
The SC ruled that the complaint was indeed premature. Under the Civil Code,
there are two (2) indispensable requisites in an action to quiet title: (1)
that the plaintiff or complainant has a legal or an equitable title to or interest in
the real property subject of the action; and (2) that a deed, claim,
encumbrance or proceeding is claimed to be casting cloud on his title.
In this case, petitioner no longer had any legal or equitable title to or interest in
the lots because of said decision of the Bureau, which was already final and
executory.

facts of the case

Nature of case: On December 11, 2000, petitioner filed a complaint with RTC for quieting
of title, injunction and other claims against Silverio Songcua, the secretary of DENR and the
regional executive director of DENR of Tuguegarao, Cagayan.
Claim of petitioner: Petitioner alleged that it is the lawful and absolute owner of two parcels of
land, together with the two-story building thereon, situatied in Santiago City. It claims that the
property originally belonged to Marcelina Ordoo, who then sold it to the Spouses Valdez, who
then sold it to them (petitioner). They allege that they have been in possession of the land for 30
years.
Alleged cloud on title: A cloud exists on the propertys title because of an invalid 1985
decision of the Bureau of Lands that rejected the sales applications of the predecessors-ininterest for lots. This decision also ordered all those in privity with them (specifically herein
petitioner) to vacate lots and remove improvements thereon.
DENR secretary affirmed this decision. Recourse to the Office of the President had been
unavailing, so DENR issued writs of execution pursuant to the President's decision.
Defense of Respondent: Pascual moved to dismiss the complaint for failure to state cause of
action. He argued that the petitioner had no legal right to file the complaint since the final and
executory Bureau of Lands decision ruled that the petitioner was not entitled to possess the lots.
RTC's Ruling: Denied the motion to dismiss. The decision of the Bureau of Lands was not yet
final since the Office of the President's ruling on the appeal was unavailable.
CA's Ruling: CA set aside the RTC .It ruled that the Bureau of Lands decision, being final and
executory, is binding and conclusive upon the petitioner. Even assuming that the OPs ruling on
1

the appeal was still unavailable, the RTC should have dismissed the complaint for prematurity;
an action to quiet title is not the proper remedy from an adverse decision issued by
an administrative agency in the exercise of its quasi-judicial function.

issue

WoN the complaint of petitioner was premature for failing to state a cause of action YES. CA
properly set aside RTC Ruling. The action of petitioner was indeed premature because
it was clear that it no longer had any legal or equitable title over the lots.

Ratio
1) The SC first discussed the concept of a cause of action.
Definition: A cause of action is the act or omission by which a party violates a right of another.
Three essential elements: (1) a right in favor of the plaintiff by whatever means and whatever
law it arises; (2) the correlative obligation of the defendant to respect such right; and (3) the act
or omission of the defendant violates the right of the plaintiff. If any of these elements is absent,
the complaint becomes vulnerable to a motion to dismiss on the ground of failure to state a
cause of action.
Failure to state a cause of action refers to the insufficiency of allegation in the pleading. In
resolving a motion to dismiss based on the failure to state a cause of action only the facts
alleged in the complaint must be considered. The test is whether the court can render a valid
judgment on the complaint based on the facts alleged and the prayer asked for.
2) The SC the essential requisites in an action to quiet title.
Under Articles 476 and 477 of the Civil Code, there are two (2) indispensable
requisites in an action to quiet title: (1) that the plaintiff or complainant has a legal or an
equitable title to or interest in the real property subject of the action; and (2) that a deed, claim,
encumbrance or proceeding is claimed to be casting cloud on his title.
APPLIED: In this case, it is clear that the petitioner no longer had any legal or equitable title to
or interest in the lots. The petitioners status as possessor and owner of the lots had been settled
in the final and executory December 4, 1985 decision of the Bureau of Lands that the DENR
Secretary and the OP affirmed on appeal. Thus, the petitioner is not entitled to the possession
and ownership of the lots.
The decisions and orders of administrative agencies, such as the Bureau of Lands,
rendered pursuant to their quasi-judicial authority, upon finality, have the force and binding
effect of a final judgment within the purview of the doctrine of res judicata. Thus, the petitioner is
now barred from challenging the validity of the final and executory Bureau of Lands December 4,
1985 decision.