Title
Alberto vs. Spouses Flores
Case
G.R. No. 237514
Decision Date
Feb 10, 2021
The Malits claimed ownership of Lot No. 1298, confirmed by a 1959 court decision. Respondents obtained a free patent over the land, later deemed void by the Supreme Court as it was private property, not public domain. Fraud was proven, and laches did not apply.
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Case Digest (G.R. No. 237514)

Facts:

  1. Ownership Claim by the Malits

    • Helen M. Alberto (petitioner) and her siblings, Aurora M. Dabu and Corazon M. Maninang (collectively, the Malits), claimed ownership of Lot No. 1298 of the Lubao Cadastre, Pampanga, through inheritance from their mother, Barbara Vitug.
    • The Malits' ownership was confirmed by a 1959 Decision of the Court of First Instance of Pampanga in Cadastral Case No. 40, which declared them as owners of the land.
    • The land was declared for taxation purposes in 1973 under Tax Declaration No. 9247 in the names of Orlando and Manuel Malit, who later sold their shares in 1988.
  2. Respondents' Free Patent Application

    • In May 2008, respondents Nicasio Flores, Jr. and Perlita Flores applied for a free patent over Lot No. 1298, which was granted by the Community Environment and Natural Resources Office (CENRO) and the Provincial Environment and Natural Resources Office (PENRO).
    • On January 21, 2009, respondents were issued Free Patent No. 035408-09-1197, and subsequently, the Registry of Deeds of Pampanga issued Katibayan ng Orihinal na Titulo Blg. 14447 in their names.
  3. Allegations of Fraud

    • The Malits alleged that respondents procured the free patent through fraud, as Lot No. 1298 was already classified as private land by the 1959 Decision and was no longer part of the public domain.
    • They also claimed that respondents, as agricultural lessees, had recognized the Malits' ownership and could not claim possession in the concept of an owner.
  4. RTC Decision

    • The Regional Trial Court (RTC) ruled in favor of the Malits, declaring the free patent and title null and void due to fraud and lack of jurisdiction by the CENRO and PENRO over private land.
  5. CA Decision

    • The Court of Appeals (CA) reversed the RTC, holding that the Malits failed to prove fraud and that the free patent and title remained valid. The CA also applied the doctrine of laches against the Malits' claim.

Issue:

  1. Whether the CA erred in ruling that the Malits failed to prove fraud in respondents' application for a free patent.
  2. Whether the CA erred in applying the doctrine of laches against the Malits' claim.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court declared Free Patent No. 035408-09-1197 and Katibayan ng Orihinal na Titulo Blg. 14447 null and void. The Register of Deeds of Pampanga was ordered to cancel the title in its records. The RTC Decision was reinstated.


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