Facts:

The case involves petitioners Jose Abelgas, Jr. and Letecia Jusayan de Abelgas against respondents Servillano Comia, Rural Bank of Socorro, Inc., and Rural Bank of Pinamalayan, Inc. The events leading to the case began on April 4, 1971, when Comia obtained a free patent for Lot No. 919-B, located in Pinamalayan, Oriental Mindoro, covering an area of 6,790 square meters. On May 1, 1971, Comia executed a notarized Deed of Relinquishment, Renunciation of Rights and Quitclaim, voluntarily conveying a 3,000-square-meter portion of Lot No. 919-B to the spouses Abelgas. The deed stated that this portion was the sole property of the spouses and had been included in Comia's title only because it adjoined his land. Following this, the Register of Deeds canceled Comia's Original Certificate of Title (OCT) No. P-8553 and issued Transfer Certificate of Title (TCT) No. T-46030 in the names of Comia and the spouses as co-owners.

The spouses subsequently subdivided their 3,000-squa...

Facts:

1. Property Acquisition and Free Patent:

   • On 4 April 1971, Servillano Comia obtained a free patent over Lot No. 919-B, a 6,790-square-meter property in Pinamalayan, Oriental Mindoro. The property was registered under Original Certificate of Title (OCT) No. P-8553 on 26 April 1976.

2. Deed of Relinquishment and Renunciation of Rights:

   • On 1 May 1971, Comia executed a notarized Deed of Relinquishment, Renunciation of Rights, and Quitclaim, voluntarily conveying a 3,000-square-meter portion of Lot No. 919-B to spouses Jose Abelgas, Jr. and Letecia Jusayan de Abelgas. The Deed stated that the 3,000-sqm portion belonged to the spouses and was only included in Comia’s title because it adjoined his land.

3. Issuance of New Titles:

   • The Register of Deeds cancelled OCT No. P-8553 and issued Transfer Certificate of Title (TCT) No. T-46030 on 3 May 1971, naming Comia and the Abelgas spouses as co-owners of Lot No. 919-B. The Abelgas spouses subdivided their 3,000-sqm portion into 12 lots, evidenced by TCT Nos. T-46374 to T-46375.

4. Mortgages and Foreclosure:

   • The Abelgas spouses used the subdivided lots as collateral for loans from Rural Bank of Pinamalayan, Inc. (RBPI), Rural Bank of Socorro, Inc. (RBSI), and the Philippine National Bank (PNB). They defaulted on their loans, leading to foreclosure and auction sales. RBPI and RBSI acquired the properties through foreclosure.

5. Comia’s Complaint:

   • Comia filed a Complaint for cancellation and recovery of title, alleging that the Deed of Relinquishment was fictitious and that he remained the sole owner of Lot No. 919-B. He sought the cancellation of subsequent titles issued to the Abelgas spouses and the banks.

6. RTC Decision:

   • The Regional Trial Court (RTC) dismissed Comia’s Complaint, ruling that the Deed was valid and that the mortgages in favor of the banks were exempt from the prohibition under the Public Land Act.

7. CA Decision:

   • The Court of Appeals (CA) reversed the RTC, declaring the Deed and the mortgages null and void for violating Section 118 of the Public Land Act, which prohibits alienation of free patent lands within five years of issuance. The CA ordered the cancellation of the titles and reinstatement of OCT No. P-8553 in Comia’s name.

Issue:

1. Whether the Deed of Relinquishment, Renunciation of Rights, and Quitclaim executed by Comia in favor of the Abelgas spouses is null and void for violating Section 118 of the Public Land Act.
2. Whether the mortgages executed by the Abelgas spouses in favor of RBPI and RBSI are valid or void for violating the same provision.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court ruled that the Deed of Relinquishment and the mortgages were valid. The CA Decision was reversed, and the RTC Decision was reinstated.