This case concerns a land dispute over a 28,099-square-meter parcel in Barrio Abatan, Benguet. Rosita Sadca's father, Acay, was granted a free patent for the land in 1975. Upon Acay's death, the land was passed to Sadca. In 1990, Sadca subdivided and sold portions of the land to several buyers. In 2002, the Republic of the Philippines filed a complaint seeking to cancel the titles and revert the land, alleging the land was in a protected area and that Acay committed fraud. The Court of Appeals dismissed the complaint, finding that Acay satisfied free patent requirements, the buyers were purchasers in good faith, and the Republic
This case concerns a land dispute over a 28,099-square-meter parcel in Barrio Abatan, Benguet. Rosita Sadca's father, Acay, was granted a free patent for the land in 1975. Upon Acay's death, the land was passed to Sadca. In 1990, Sadca subdivided and sold portions of the land to several buyers. In 2002, the Republic of the Philippines filed a complaint seeking to cancel the titles and revert the land, alleging the land was in a protected area and that Acay committed fraud. The Court of Appeals dismissed the complaint, finding that Acay satisfied free patent requirements, the buyers were purchasers in good faith, and the Republic
This case concerns a land dispute over a 28,099-square-meter parcel in Barrio Abatan, Benguet. Rosita Sadca's father, Acay, was granted a free patent for the land in 1975. Upon Acay's death, the land was passed to Sadca. In 1990, Sadca subdivided and sold portions of the land to several buyers. In 2002, the Republic of the Philippines filed a complaint seeking to cancel the titles and revert the land, alleging the land was in a protected area and that Acay committed fraud. The Court of Appeals dismissed the complaint, finding that Acay satisfied free patent requirements, the buyers were purchasers in good faith, and the Republic
This case concerns a land dispute over a 28,099-square-meter parcel in Barrio Abatan, Benguet. Rosita Sadca's father, Acay, was granted a free patent for the land in 1975. Upon Acay's death, the land was passed to Sadca. In 1990, Sadca subdivided and sold portions of the land to several buyers. In 2002, the Republic of the Philippines filed a complaint seeking to cancel the titles and revert the land, alleging the land was in a protected area and that Acay committed fraud. The Court of Appeals dismissed the complaint, finding that Acay satisfied free patent requirements, the buyers were purchasers in good faith, and the Republic
Case: REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE REGIONAL EXECUTIVE
DIRECTOR OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES (DENR) FOR THE CORDILLERA ADMINISTRATIVE REGION (CAR), PETITIONER, VS. ROSITA SADCA, SPOUSES MARCENIO LESINO AND ELIZABETH BAGUINAY, SPOUSES BENITO BENTADAN AND HELEN DIMAS, SPOUSES ROMEO FONTANILLA AND FELOMINA DAGAS, RESPONDENTS. | G.R. No. 218640., November 29, 2021 Digested by: Rizzie P. Soliman
Recit-Ready Doctrine (Simplified Take Away):
Summary: This case concerns a dispute over the ownership of a parcel of land in Barrio Abatan, Mankayan, Benguet. The Republic of the Philippines filed a complaint for the cancellation of a free patent and an original certificate of title issued in favor of Rosita Sadca (Acay), alleging that the land awarded to Acay was located within the Mount Data National Park and National Forest and was, therefore, not alienable. The Republic also claimed that Acay had made false representations in his free patent application. The Regional Trial Court dismissed the Republic's complaint, and this decision was affirmed by the Court of Appeals. The Court of Appeals found that Acay, a member of the Kankana-ey Tribe, had satisfied the requirements for the approval of his free patent application and that the lot buyers were purchasers in good faith. Hence, the Republic's appeal was denied.
Facts: ● Acay applied for a free patent over a 28,099-square-meter parcel of land in Barrio Abatan, Mankayan, Benguet.
● The Director of Lands issued Free Patent No. (1-2) 1207 in Acay's favor on August 29, 1975, and Original Certificate of Title No. P- 7888 was issued in Acay's name.
● Acay died intestate on May 26, 1986, and the heirs extrajudicially settled the properties among themselves, allocating the Barrio Abatan lot to Rosita Sadca, Acay's daughter.
● On June 24, 1987, the Original Certificate of Title No. P-788 was canceled and replaced by Transfer Certificate of Title No. T-22747 was issued in Rosita's name.
● On April 30, 1990, Rosita subdivided the lot into 13 parcels and sold them to different individuals.
● On August 26, 2002, the Republic filed a complaint for the cancellation of the free patent and original certificate of title, and the reversion of the Barrio Abatan lot, alleging that the lot awarded to Acay was located inside the Mount Data National Park and National Forest and was not alienable. The Republic also claimed that Acay made false representations in his free patent application.
Issues: ● Whether Acay's free patent over the disputed land was valid. ● Whether the lot buyers were purchasers in good faith. ● Whether the Republic had proven that Acay committed fraud in his free patent application.
Ruling: The Court of Appeals affirmed the Regional Trial Court's decision, dismissing the Republic's complaint.
Validity of Acay's Free Patent: The Court of Appeals found that Acay, as a member of the Kankana-ey Tribe, satisfied the requirements for the approval of his free patent application. He had possessed and occupied the land for at least 30 years, as required by Section 48(c) of the Public Land Act.
Lot Buyers as Purchasers in Good Faith: The Court of Appeals ruled that the lot buyers were purchasers in good faith since the title awarded to Acay, and later to Rosita, was contested only 27 years after Acay's free patent application was granted. The lot had been possessed without question of their ownership or possession prior to the complaint for reversion.
Absence of Proven Fraud: The Court of Appeals held that the Republic failed to substantiate its claim that Acay committed fraud in his free patent application or that there was irregularity in its approval.
Conclusion: The Court of Appeals affirmed the decision of the Regional Trial Court, dismissing the Republic's complaint for the cancellation of a free patent and an original certificate of title issued in favor of Rosita Sadca (Acay). The court found that Acay's free patent was valid, the lot buyers were purchasers in good faith, and there was no evidence of fraud in Acay's free patent application.
Facts:
● Land Application: Rosita Sadca (commonly referred to as Acay) applied for a free patent over a parcel of land measuring 28,099 square meters located in Barrio Abatan, Mankayan, Benguet.
● Free Patent Issued: On August 29, 1975, the Director of Lands issued Free Patent No. (1-2) 1207 in favor of Acay for the said parcel of land. Subsequently, the Original Certificate of Title No. P- 7888 was issued in Acay's name.
● Acay's Demise: On May 26, 1986, Acay passed away intestate, leaving behind several properties. The heirs engaged in an extrajudicial settlement of these properties, and the lot in Barrio Abatan was allocated to Acay's daughter, Rosita. ● Transfer of Title: On June 24, 1987, Original Certificate of Title No. P-788 was canceled and replaced by Transfer Certificate of Title No. T-22747 was issued in Rosita's name.
● Subdivision and Sale: On April 30, 1990, Rosita subdivided the lot into 13 parcels and subsequently sold these parcels to different individuals, including Spouses Marcenio Lesino and Elizabeth Baguinay, Spouses Benito Bentadan and Helen Dimas, and Spouses Romeo Fontanilla and Felomina Dagas. Each of the lot buyers was issued a corresponding certificate of title.
● Republic's Complaint: On August 26, 2002, the Republic of the Philippines initiated legal action by filing a complaint seeking the cancellation of the free patent and original certificate of title issued to Acay, as well as the reversion of the Barrio Abatan lot. The Republic alleged that the land awarded to Acay was situated within the Mount Data National Park and National Forest and was therefore not alienable. Additionally, the Republic claimed that Acay had made false representations in his free patent application.
Issue: ● Validity of Acay's Free Patent: Whether the free patent granted to Rosita Sadca (Acay) for the parcel of land in Barrio Abatan, Mankayan, Benguet, was valid, considering that it was alleged to be located within the Mount Data National Park and National Forest.
● Status of Lot Buyers as Purchasers in Good Faith: Whether the individuals who purchased portions of the subdivided land from Rosita Sadca, such as Spouses Marcenio Lesino and Elizabeth Baguinay, Spouses Benito Bentadan and Helen Dimas, and Spouses Romeo Fontanilla and Felomina Dagas, were purchasers in good faith. This question pertains to their rights over the land they acquired, given the controversy surrounding the original title.
● Allegations of Fraud in Free Patent Application: Whether the Republic of the Philippines successfully established that Acay made false representations or committed fraud in his free patent application, leading to the issuance of the original certificate of title. The outcome of this issue may affect the validity of Acay's title and, by extension, the titles subsequently issued to the lot buyers.
Ruling: The Petition for Review on Certiorari is DENIED. The May 26, 2015 Decision of the Court of Appeals in CA-GR. CV No. 100698 is AFFIRMED. The Complaint of the Republic of the Philippines for cancellation of free patent and reversion of land is DISMISSED for the petitioner's failure to prove by clear and convincing evidence that Sadca Acay's titles are invalid.
