327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a trial court simultaneously grant a motion for
reconsideration and render a summary judgment in favor of the respondents,
thereby denying the petitioner the opportunity to oppose or appeal both
decisions in a single order, without violating due process?
G.R. No. 224076 | July 28, 2020
Facts of the Case:
On May 13, 2010, the Republic of the Philippines,
represented by the Department of Environment and Natural Resources (DENR) and
the Office of the Solicitor General (OSG), filed a complaint seeking the
cancellation and reversion of several certificates of title issued to various
respondents. The Republic argued that the land in question, located in
Calatagan, Batangas, was inalienable public land and had been fraudulently
titled to private entities. This claim was based on a prior Supreme Court
ruling in Republic v. Ayala y Cia, which had declared the land as part
of the seashore, making it inalienable.
The titles in question were initially issued as Original
Certificates of Title (OCT) Nos. 921 to 926 and then transferred through
several corporations. The Republic sought to cancel these titles, arguing that
the land was subject to a Fishpond Lease Agreement (FLA) issued to Prudencia
Conlu, and therefore could not have been privately titled.
Respondents denied these allegations and argued that the
land had already been classified as alienable and disposable as early as May
14, 1969, prior to the issuance of the FLA. They claimed that the titles were
lawfully issued, and they had purchased the property for value.
The case was raffled to the Regional Trial Court (RTC) of
Balayan, Batangas, Branch 11, under Civil Case No. 4929. After receiving
answers from some of the respondents, the Republic failed to respond to a
Request for Admission filed by the respondents. Consequently, respondents filed
a Motion for Summary Judgment.
The trial court initially denied the motion but later
reconsidered its decision, rendering a summary judgment in favor of the
respondents on September 3, 2013. The court based its ruling on the Republic's
implied admission of facts by failing to answer the Request for Admission.
The Republic filed a petition for certiorari with the Court
of Appeals (CA), arguing that the trial court committed grave abuse of
discretion by rendering a summary judgment without due process. The CA
dismissed the petition on technical grounds, stating that the proper remedy was
an appeal under Rule 45, not a petition for certiorari under Rule 65.
Issue at the Supreme Court:
Did the Court of Appeals correctly dismiss the Republic's
petition for certiorari, or did the trial court commit grave abuse of
discretion in rendering a summary judgment, thereby violating the Republic's
right to due process?
Supreme Court Decision:
The Supreme Court found that the trial court committed grave
abuse of discretion when it simultaneously granted the respondents' motion for
reconsideration and rendered a summary judgment in one order, depriving the
Republic of the opportunity to seek reconsideration or appeal. This amounted to
a violation of due process.
The Court held that the issues in the case—whether the land
was alienable and whether the titles were fraudulently issued—were genuine
issues of fact that could not be resolved through summary judgment. The Court
reiterated that summary judgment is appropriate only when there is no genuine
issue as to any material fact, which was not the case here.
Accordingly, the Supreme Court reversed and set aside
the rulings of the Court of Appeals and the trial court. The case was remanded
to the RTC for trial on the merits.
Dispositive Portion:
The petition is GRANTED. The Resolutions of the Court
of Appeals dated September 24, 2015, and April 11, 2016, are REVERSED AND
SET ASIDE. The Orders of the Regional Trial Court of Balayan, Batangas,
Branch 11, dated September 3, 2013, and December 18, 2013, are ANNULLED.
The RTC is directed to REOPEN THE CASE, conduct pre-trial, and proceed
to a full trial on the merits with dispatch.
Should courts have more stringent safeguards against issuing
summary judgments in cases where there are substantial factual disputes, to
prevent potential violations of due process?
Doctrines Discussed:
- Grave
Abuse of Discretion – Occurs when a court acts in a capricious,
whimsical, arbitrary, or despotic manner. In this case, the trial court's
simultaneous issuance of reconsideration and summary judgment without
allowing the Republic to respond constituted grave abuse of discretion.
- Summary
Judgment – Appropriate only when there is no genuine issue as to any
material fact. The Court emphasized that issues of fraud and the alienable
status of the land were genuine issues of fact that required a full trial.
- Rule
26 of the Rules of Court (Request for Admission) – A party is not
required to respond to requests for admission that merely reiterate issues
already raised in the pleadings, as such requests are considered
redundant.
- Due
Process – The right to due process is violated when a party is
deprived of the opportunity to present its case fully or to seek
reconsideration of a ruling, as happened when the trial court rendered a
summary judgment in a single order.
- Appeal
vs. Certiorari – The Supreme Court clarified that while the proper
remedy to assail a final judgment, such as a summary judgment, is through
an appeal (Rule 45), certiorari (Rule 65) is available when there is a
clear showing of grave abuse of discretion amounting to lack or excess of
jurisdiction, particularly when due process rights are violated. In this
case, the Republic was justified in filing a petition for certiorari since
the trial court's actions deprived it of its right to due process.
- Implied
Admission Under Rule 26 – Implied admissions under Rule 26 occur when
a party fails to respond to a request for admission. However, such a
request must be valid and not a mere repetition of matters already at
issue. The Supreme Court ruled that the request for admission served by
the respondents in this case was a mere reiteration of their previous
pleadings, making the Republic’s failure to respond immaterial and
unjustifying the summary judgment.
- Genuine
Issues of Fact – The Supreme Court reaffirmed that summary judgment is
only proper when there are no genuine issues of fact that require
presentation of evidence. Here, the questions of whether the land was
alienable and whether the titles were fraudulently obtained were genuine
issues of fact that could not be resolved without a full trial. Courts
should refrain from issuing summary judgments in cases where substantial
factual disputes remain unresolved.
- Simultaneous
Resolution of Motions – The Court ruled that it was improper for the
trial court to simultaneously grant the motion for reconsideration and
issue a summary judgment in a single order. This procedural irregularity
deprived the Republic of the chance to file a motion for reconsideration
before the final judgment was issued, thus violating its right to due
process.
🎓 PHILIPPINE
JURISPRUDENCE DIGEST | For Law Students & Bar Examinees
By: Your Law Professor in AI | #BarReviewSeries
🔍 In this content, we
explore the Supreme Court decision in Republic v. Datuin—a
crucial case on summary judgment, due process, and remedial law.
This content will help law students and baristas easily recall key
doctrines and better understand civil procedure pitfalls—especially
in cases involving genuine factual issues.
📚 CASE NATURE:
Remedial Law – Civil Procedure: Rule 26 (Request for
Admission) & Rule 35 (Summary Judgment)
📌 Case Title:
Republic of the Philippines v. Susan Datuin, et al.
📌 Date of
Promulgation: July 28, 2020
📄 The Republic
sought the cancellation of land titles allegedly issued over inalienable
public lands, worth over ₱12 million. The RTC granted a summary judgment
against the Republic, citing its failure to respond to a request for
admission. The Court of Appeals dismissed the Republic's certiorari
petition.
The Supreme Court reversed, ruling that grave
abuse of discretion was committed, and that due process was violated
by rendering judgment without trial.
💡 Should trial courts
rigidly apply procedural shortcuts like summary judgment even at the risk of
ignoring clear factual disputes?
💬 Comment your
thoughts. Don’t forget to like, save, and subscribe.
📘 TOP 10 IMPORTANT
DOCTRINES IN REPUBLIC v. DATUIN
(All citations and references taken from the Supreme
Court ruling in G.R. No. 224076)
- Summary
judgment is proper only if no genuine factual issue exists.
➤ Factual disputes like land classification and title fraud require trial. (p. 47) - Failure
to answer a Request for Admission does not mean blanket admission.
➤ Especially if the request merely reiterates matters already disputed in pleadings. (p. 45) - Request
for Admission cannot cover the heart of the controversy.
➤ Used to clarify, not decide, core disputed matters. (p. 45-46) - Simultaneous
granting of reconsideration and summary judgment is grave abuse.
➤ It deprives the losing party of the chance to challenge each ruling separately. (p. 49) - Certiorari
is proper when due process is violated—even if appeal is available.
➤ Exception to the general rule of remedies. (p. 41) - Doctrine
of “implied admission” under Rule 26 must not be abused.
➤ Requests must not be used to trap parties or circumvent trials. (p. 45-46) - Existence
of factual disputes nullifies summary judgment.
➤ E.g., land's classification as alienable vs. inalienable is a factual matter. (p. 47) - Due
process requires opportunity to be heard before judgment.
➤ No party should be condemned unheard—even in procedural shortcuts. (p. 48) - Reiteration
of defenses in both Answer and Request for Admission is redundant.
➤ Republic was not bound to re-admit what it already denied. (p. 44) - Use
of Rule 26 must aim to expedite—not replace—trial.
➤ Improper usage leads to delay, not efficiency. (p. 45)
📢 DISCLAIMER:
This video is for educational purposes only. We do not
guarantee infallibility. All content was prepared using premium
artificial intelligence and based on official Supreme Court documents.
❓ FREQUENTLY ASKED QUESTIONS:
Q1: Can the Supreme Court nullify a summary judgment
even if it seems procedurally correct?
A: Yes, if due process is violated or there is grave
abuse of discretion.
Q2: What is the core purpose of a Request for
Admission?
A: To expedite trial by admitting facts not in
dispute—not to decide the controversy itself.
Q3: Is certiorari a proper remedy against summary
judgment?
A: Yes, if the judgment was issued with grave abuse
of discretion or without due process.
Q4: What’s considered a “genuine issue of fact”?
A: One that requires presentation of evidence, like
whether land is alienable or not.
Q5: Why was the RTC’s simultaneous issuance of two
orders problematic?
A: It deprived the Republic of the right to seek
reconsideration separately—violating due process.
🎓 Like, share, save
this post, and subscribe for more case digests and legal doctrines
explained!
🎓 QUIZZER INTRODUCTION
– Republic v. Datuin | Summary Judgment & Due Process
Welcome to today’s legal quizzer! This episode is based on
the landmark Supreme Court case:
Republic of the Philippines vs. Susan Datuin, et al.
G.R. No. 224076 | Promulgated: July 28, 2020
This case falls under Remedial Law—particularly civil
procedure, focusing on summary judgment, requests for admission,
and the right to due process.
The Republic sought to cancel titles to land allegedly
classified as inalienable public domain. The trial court rendered a summary
judgment in favor of private parties, citing the Republic’s failure to
respond to a request for admission. The Court of Appeals dismissed the
Republic's certiorari petition. However, the Supreme Court reversed,
ruling that the RTC committed grave abuse of discretion for depriving
the Republic of a full trial on genuine issues of fact.
📝 Answer key will be
provided at the end of the video—stay tuned and test your legal insight!
🔥 10 HOTS Multiple Choice
Questions (Easy Difficulty)
1. What was the main reason the Republic filed a
complaint against the respondents in this case?
A. To collect unpaid real property taxes
B. To eject the respondents from a leased building
C. To cancel land titles over inalienable public land
D. To enforce a contract of sale
2. What procedural action did the trial court
initially deny but later granted in favor of the respondents?
A. Motion to declare the Republic in default
B. Motion for summary judgment
C. Motion for preliminary injunction
D. Motion to dismiss the complaint
3. Why did the Supreme Court consider the trial
court's actions as grave abuse of discretion?
A. It failed to require a bond before issuing an order
B. It ruled without conducting any hearing
C. It rendered summary judgment despite genuine factual
issues
D. It allowed a change of venue
4. What did the Republic allegedly fail to do, which
led the trial court to consider certain facts as admitted?
A. Attend the pre-trial conference
B. Present evidence within the deadline
C. File a motion for reconsideration
D. Respond to a request for admission
5. Which legal remedy did the Republic pursue before
the Court of Appeals to challenge the summary judgment?
A. Petition for review
B. Petition for certiorari
C. Appeal by notice of appeal
D. Petition for prohibition
6. What type of land was at the center of the dispute
in this case?
A. Residential land
B. Inalienable public land
C. Urban commercial land
D. Ancestral domain land
7. What was the ruling of the Court of Appeals
regarding the Republic’s petition?
A. Granted the petition for certiorari
B. Affirmed the trial court’s denial of summary judgment
C. Dismissed the petition for using the wrong remedy
D. Reversed the trial court’s order and remanded the case
8. What important procedural rule was central to the
conflict in this case?
A. Joinder of parties
B. Request for admission
C. Bill of particulars
D. Intervention
9. What did the Supreme Court instruct the trial
court to do after nullifying its prior orders?
A. Re-issue the titles to the respondents
B. Dismiss the complaint for lack of merit
C. Reopen the case and conduct a full trial
D. Transfer the case to a different court
10. What core constitutional right did the Supreme
Court find to have been violated?
A. Right to equal protection
B. Right against self-incrimination
C. Right to speedy disposition of cases
D. Right to due process
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