Lawyerly

GR No. 203655

2015-09-07

VELASCO JR., J.

Estoppels against the public are little favored. They should not be invoked except in a rare and unusual circumstances, and may not be invoked where they would operate to defeat the effective operation of a policy adopted to protect the public. They must be applied with circumspection and should be applied only in those special cases where the interests of justice clearly require it. Nevertheless, the government must not be allowed to deal dishonorably or capriciously with its citizens, and must not play an ignoble part or do a shabby thing; and subject to limitations x x x, the doctrine of equitable estoppel may be invoked against public authorities as well as against private individuals.[18]

GR No. 203655

2015-03-18

SM LAND v. BASES CONVERSION

VELASCO JR., J.

Estoppels against the public are little favored. They should not be invoked except [in rare] and unusual circumstances, and may not be invoked where they would operate to defeat the effective operation of a policy adopted to protect the public. They must be applied with circumspection and should be applied only in those special cases where the interests of justice clearly require it. Nevertheless, the government must not be allowed to deal dishonorably or capriciously with its citizens, and must not play an ignoble part or do a shabby thing; and subject to limitations . . ., the doctrine of equitable estoppel may be invoked against public authorities as well as against private individuals.[32] (emphasis added)

GR No. 187485

2013-02-12

CIR v. SAN ROQUE POWER CORPORATION

CARPIO, J.

II. The CTA En Banc erred in retroactively applying the Aichi ruling in denying the petition in this instant case.[42]

GR No. 176579

2012-10-09

HEIRS OF WILSON P. GAMBOA v. FINANCE SECRETARY MARGARITO B. TEVES

CARPIO, J.

The government cannot plausibly hide behind the mantle of its general immunity to resist the application of this equitable principle for "[t]he rule on non-estoppel of the government is not designed to perpetrate an injustice."[108] Hence, this Court has allowed several exceptions to the rule on the government's non-estoppel. As succinctly explained in Republic of the Philippines v. Court of Appeals:[109]

GR No. 163610

2010-09-27

HEIRS OF ENRIQUE TORING v. HEIRS OF TEODOSIA BOQUILAGA

VILLARAMA, JR., J.

Laches means the failure or neglect, for an unreasonable length of time, to do that which by exercising due diligence could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it.[35] This equitable defense is based upon grounds of public policy, which requires the discouragement of stale claims for the peace of society. Indeed, while it is true that a Torrens Title is indefeasible and imprescriptible, the registered landowner may lose his right to recover the possession of his registered property by reason of laches.[36] In this case, however, laches cannot be appreciated in respondents' favor.

GR No. 167232

2009-07-31

D.B.T. MAR-BAY CONSTRUCTION v. RICAREDO PANES

NACHURA, J.

Moreover, it may be stressed that there was no ample proof that DBT participated in the alleged fraud. While factual issues are admittedly not within the province of this Court, as it is not a trier of facts and is not required to re-examine or contrast the oral and documentary evidence anew, we have the authority to review and, in proper cases, reverse the factual findings of lower courts when the findings of fact of the trial court are in conflict with those of the appellate court.[59] In this regard, we reviewed the records of this case and found no clear evidence that DBT participated in the fraudulent scheme. In Republic v. Court of Appeals,[60] this Court gave due importance to the fact that the private respondent therein did not participate in the fraud averred. We accord the same benefit to DBT in this case. To add, DBT is an innocent purchaser for value and good faith which, through a dacion en pago duly entered into with B.C. Regalado, acquired ownership over the subject property, and whose rights must be protected under Section 32[61] of P.D. No. 1529.

GR No. 168661

2007-10-26

ESTATE OF LATE JESUS S. YUJUICO v. REPUBLIC

VELASCO JR., J.

In Republic v. Court of Appeals, where the title of an innocent purchaser for value who relied on the clean certificates of the title was sought to be cancelled and the excess land to be reverted to the Government, we ruled that "[i]t is only fair and reasonable to apply the equitable principle of estoppel by laches against the government to avoid an injustice to innocent purchasers for value (emphasis supplied)."[22] We explained:Likewise time-settled is the doctrine that where innocent third persons, relying on the correctness of the certificate of title, acquire rights over the property, courts cannot disregard such rights and order the cancellation of the certificate. Such cancellation would impair public confidence in the certificate of title, for everyone dealing with property registered under the Torrens system would have to inquire in every instance whether the title has been regularly issued or not. This would be contrary to the very purpose of the law, which is to stabilize land titles. Verily, all persons dealing with registered land may safely rely on the correctness of the certificate of title issued therefore, and the law or the courts do not oblige them to go behind the certificate in order to investigate again the true condition of the property. They are only charged with notice of the liens and encumbrances on the property that are noted on the certificate.[23]

GR No. 163130

2007-09-07

SAN ROQUE REALTY v. REPUBLIC

NACHURA, J.

The general rule is that the State cannot be put in estoppel or laches by the mistakes or errors of its officials or agents.[38] This rule, however, admits of exceptions. One exception is when the strict application of the rule will defeat the effectiveness of a policy adopted to protect the public[39] such as the Torrens system.

GR NO. 153726

2007-03-28

REPUBLIC v. DEMOCRITO T. MENDOZA

CHICO-NAZARIO, J.

While the general rule is that the State cannot be put in estoppel by the mistakes or errors of its officials or agents, like all general rules, this is also subject to exceptions. We recognized such exceptions in Republic v. Court of Appeals,[30] to wit -

GR NO. 133168

2006-03-28

REPUBLIC v. BENJAMIN GUERRERO

GARCIA, J.

Upon its registration, the land falls under the operation of Act No. 496 and becomes registered land. Time and again, we have said that a Torrens certificate is evidence of an indefeasible title to property in favor of the person whose name appears thereon.[11]

GR No. 126223

2000-11-15

PHILIPPINE AMERICAN LIFE INSURANCE COMPANY v. CA

GONZAGA-REYES, J.

Death certificates, and notes by a municipal health officer prepared in the regular performance of his duties, are prima facie evidence of facts therein stated.[19] A duly-registered death certificate is considered a public document and the entries found therein are presumed correct, unless the party who contests its accuracy can produce positive evidence establishing otherwise.[20] Petitioner's contention that the death certificate is suspect because Dr. Gutierrez was not present when Florence Pulido died, and knew of Florence's death only through Ramon Piganto, does not merit a conclusion of fraud. No motive was imputed to Dr. Gutierrez for seeking to perpetuate a falsity in public records. Petitioner was likewise unable to make out any clear motive as to why Ramon Piganto would purposely lie. Mere allegations of fraud could not substitute for the full and convincing evidence that is required to prove it.[21] A failure to do so would leave intact the presumption of good faith and regularity in the performance of public duties, which was the basis of both respondent court and the trial court in finding the date of Florence Pulido's death to be as plaintiff-private respondent maintained.

	GR No. 203655 2015-09-07	SM LAND v. BASES CONVERSION VELASCO JR., J.
Estoppels against the public are little favored. They should not be invoked except in a rare and unusual circumstances, and may not be invoked where they would operate to defeat the effective operation of a policy adopted to protect the public. They must be applied with circumspection and should be applied only in those special cases where the interests of justice clearly require it. Nevertheless, the government must not be allowed to deal dishonorably or capriciously with its citizens, and must not play an ignoble part or do a shabby thing; and subject to limitations x x x, the doctrine of equitable estoppel may be invoked against public authorities as well as against private individuals.[18]
	GR No. 203655 2015-03-18	SM LAND v. BASES CONVERSION VELASCO JR., J.
Estoppels against the public are little favored. They should not be invoked except [in rare] and unusual circumstances, and may not be invoked where they would operate to defeat the effective operation of a policy adopted to protect the public. They must be applied with circumspection and should be applied only in those special cases where the interests of justice clearly require it. Nevertheless, the government must not be allowed to deal dishonorably or capriciously with its citizens, and must not play an ignoble part or do a shabby thing; and subject to limitations . . ., the doctrine of equitable estoppel may be invoked against public authorities as well as against private individuals.[32] (emphasis added)
	GR No. 187485 2013-02-12	CIR v. SAN ROQUE POWER CORPORATION CARPIO, J.
II. The CTA En Banc erred in retroactively applying the Aichi ruling in denying the petition in this instant case.[42]
	GR No. 176579 2012-10-09	HEIRS OF WILSON P. GAMBOA v. FINANCE SECRETARY MARGARITO B. TEVES CARPIO, J.
The government cannot plausibly hide behind the mantle of its general immunity to resist the application of this equitable principle for "[t]he rule on non-estoppel of the government is not designed to perpetrate an injustice."[108] Hence, this Court has allowed several exceptions to the rule on the government's non-estoppel. As succinctly explained in Republic of the Philippines v. Court of Appeals:[109]
	GR No. 163610 2010-09-27	HEIRS OF ENRIQUE TORING v. HEIRS OF TEODOSIA BOQUILAGA VILLARAMA, JR., J.
Laches means the failure or neglect, for an unreasonable length of time, to do that which by exercising due diligence could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it.[35] This equitable defense is based upon grounds of public policy, which requires the discouragement of stale claims for the peace of society. Indeed, while it is true that a Torrens Title is indefeasible and imprescriptible, the registered landowner may lose his right to recover the possession of his registered property by reason of laches.[36] In this case, however, laches cannot be appreciated in respondents' favor.
	GR No. 167232 2009-07-31	D.B.T. MAR-BAY CONSTRUCTION v. RICAREDO PANES NACHURA, J.
Moreover, it may be stressed that there was no ample proof that DBT participated in the alleged fraud. While factual issues are admittedly not within the province of this Court, as it is not a trier of facts and is not required to re-examine or contrast the oral and documentary evidence anew, we have the authority to review and, in proper cases, reverse the factual findings of lower courts when the findings of fact of the trial court are in conflict with those of the appellate court.[59] In this regard, we reviewed the records of this case and found no clear evidence that DBT participated in the fraudulent scheme. In Republic v. Court of Appeals,[60] this Court gave due importance to the fact that the private respondent therein did not participate in the fraud averred. We accord the same benefit to DBT in this case. To add, DBT is an innocent purchaser for value and good faith which, through a dacion en pago duly entered into with B.C. Regalado, acquired ownership over the subject property, and whose rights must be protected under Section 32[61] of P.D. No. 1529.
	GR No. 168661 2007-10-26	ESTATE OF LATE JESUS S. YUJUICO v. REPUBLIC VELASCO JR., J.
In Republic v. Court of Appeals, where the title of an innocent purchaser for value who relied on the clean certificates of the title was sought to be cancelled and the excess land to be reverted to the Government, we ruled that "[i]t is only fair and reasonable to apply the equitable principle of estoppel by laches against the government to avoid an injustice to innocent purchasers for value (emphasis supplied)."[22] We explained:Likewise time-settled is the doctrine that where innocent third persons, relying on the correctness of the certificate of title, acquire rights over the property, courts cannot disregard such rights and order the cancellation of the certificate. Such cancellation would impair public confidence in the certificate of title, for everyone dealing with property registered under the Torrens system would have to inquire in every instance whether the title has been regularly issued or not. This would be contrary to the very purpose of the law, which is to stabilize land titles. Verily, all persons dealing with registered land may safely rely on the correctness of the certificate of title issued therefore, and the law or the courts do not oblige them to go behind the certificate in order to investigate again the true condition of the property. They are only charged with notice of the liens and encumbrances on the property that are noted on the certificate.[23]
	GR No. 163130 2007-09-07	SAN ROQUE REALTY v. REPUBLIC NACHURA, J.
The general rule is that the State cannot be put in estoppel or laches by the mistakes or errors of its officials or agents.[38] This rule, however, admits of exceptions. One exception is when the strict application of the rule will defeat the effectiveness of a policy adopted to protect the public[39] such as the Torrens system.
	GR NO. 153726 2007-03-28	REPUBLIC v. DEMOCRITO T. MENDOZA CHICO-NAZARIO, J.
While the general rule is that the State cannot be put in estoppel by the mistakes or errors of its officials or agents, like all general rules, this is also subject to exceptions. We recognized such exceptions in Republic v. Court of Appeals,[30] to wit -
	GR NO. 133168 2006-03-28	REPUBLIC v. BENJAMIN GUERRERO GARCIA, J.
Upon its registration, the land falls under the operation of Act No. 496 and becomes registered land. Time and again, we have said that a Torrens certificate is evidence of an indefeasible title to property in favor of the person whose name appears thereon.[11]
	GR No. 126223 2000-11-15	PHILIPPINE AMERICAN LIFE INSURANCE COMPANY v. CA GONZAGA-REYES, J.
Death certificates, and notes by a municipal health officer prepared in the regular performance of his duties, are prima facie evidence of facts therein stated.[19] A duly-registered death certificate is considered a public document and the entries found therein are presumed correct, unless the party who contests its accuracy can produce positive evidence establishing otherwise.[20] Petitioner's contention that the death certificate is suspect because Dr. Gutierrez was not present when Florence Pulido died, and knew of Florence's death only through Ramon Piganto, does not merit a conclusion of fraud. No motive was imputed to Dr. Gutierrez for seeking to perpetuate a falsity in public records. Petitioner was likewise unable to make out any clear motive as to why Ramon Piganto would purposely lie. Mere allegations of fraud could not substitute for the full and convincing evidence that is required to prove it.[21] A failure to do so would leave intact the presumption of good faith and regularity in the performance of public duties, which was the basis of both respondent court and the trial court in finding the date of Florence Pulido's death to be as plaintiff-private respondent maintained.

REPUBLIC v. CA