This case involves a dispute over land titles issued for two parcels of land in Mariveles, Bataan. The Director of Lands initially issued a sales patent for the lands to Sunbeam Convenience Foods, but later cancelled the certificate of title and issued a new one to Coral Beach Development Corporation. The Solicitor General then filed an action for reversion before the Court of First Instance. The Court of Appeals set aside the CFI's order dismissing the case, ruling that the issue affects a matter of public concern regarding the disposition of public lands. The Supreme Court affirmed the CA's ruling, noting that the complaint alleged the lands were forest lands, which raises a material factual issue that must be resolved through a
This case involves a dispute over land titles issued for two parcels of land in Mariveles, Bataan. The Director of Lands initially issued a sales patent for the lands to Sunbeam Convenience Foods, but later cancelled the certificate of title and issued a new one to Coral Beach Development Corporation. The Solicitor General then filed an action for reversion before the Court of First Instance. The Court of Appeals set aside the CFI's order dismissing the case, ruling that the issue affects a matter of public concern regarding the disposition of public lands. The Supreme Court affirmed the CA's ruling, noting that the complaint alleged the lands were forest lands, which raises a material factual issue that must be resolved through a
This case involves a dispute over land titles issued for two parcels of land in Mariveles, Bataan. The Director of Lands initially issued a sales patent for the lands to Sunbeam Convenience Foods, but later cancelled the certificate of title and issued a new one to Coral Beach Development Corporation. The Solicitor General then filed an action for reversion before the Court of First Instance. The Court of Appeals set aside the CFI's order dismissing the case, ruling that the issue affects a matter of public concern regarding the disposition of public lands. The Supreme Court affirmed the CA's ruling, noting that the complaint alleged the lands were forest lands, which raises a material factual issue that must be resolved through a
Sunbeam Convenience Foods, Inc. vs. Court of Appeals Facts: The Director of Lands caused the issuance of a Sales Patent in favor of Sunbeam Convenience Foods, Inc., over the parcels of land both situated in Mariveles, Bataan The aforesaid Sales Patent was registered with the Register of Deeds of Bataan who in turn issued certificate of titles in favor of Sunbeam Convenience Foods, Inc., for the two parcels of land. Subsequently, the certificate of title was cancelled and a new certificate of titles was issued over the said parcels of land, both in favor of Coral Beach Development Corporation. The Solicitor General instituted before the Court of First Instance of Bataan, an action for reversion. Petitioners filed a Motion to Dismiss on the action for reversion. The then CFI of Bataan dismissed the complaint adopting mainly the theory that since the titles sought to be cancelled emanated from the administrative act of the Bureau of Lands Director, the latter, not the courts, had jurisdiction over the disposition of the land. The CA gave due course to the petition for certiorari by the Republic and had set aside the Order of Dismissal rendered by the Court of First Instance. It had then ordered the the lower court to receive the answers of SUNBEAM and CORAL BEACH in the action for reversion. Hence, Sunbeam and Coral Beach filed a petition for review. Issue: Whether or not he CA is correct in setting aside the order of dismissal by the CFI Bataan? Ruling: The Court of Appeals is correct to give due course to the petition considering that the issue affected a matter of public concern which is the disposition of the lands of our matrimony No less than the Constitution protects its policy. An important factual issue raised in the complaint was the classification of the lands as forest lands. This material allegation stated in the Republic's complaint was never denied by the petitioner. If it is true that the lands are forest lands, then all these proceedings become moot and academic. Land remains unclassified land until it is released therefrom and rendered open to disposition. The adherence to the Regalian doctrine subjects all agricultural, timber, and mineral lands to the dominion of the State. Thus, before any land may be declassified from the forest group and converted into alienable or disposable land for agricultural or other purposes, there must be a positive act from the government. Even rules on the confirmation of imperfect titles do not apply unless and until the land classified as forest land is released in an official proclamation to that effect so that it may form part of the disposable agricultural lands of the public domain. The mere fact that a title was issued by the Director of Lands does not confer any validity on such title if the property covered by the title or patent is part of the public forest. The only way to resolve this question of fact as to the classification of the land is by remanding the case to the lower court for a full- dress trial on the issues involved.