G.R. No. 237514 - Alberto vs. Spouses Flores

Petitioner Helen M. Alberto, together with her siblings (collectively known as the Malits), claimed exclusive ownership in fee simple of Lot No. 1298 of the Lubao Cadastre in San Roque Arbol, Lubao, Pampanga.
The Malits inherited the subject land from their mother, Barbara Vitug, whose title was surveyed between 1932 and 1935, and their ownership was confirmed by a decision rendered on October 28, 1959 by the Court of First Instance of Pampanga, Fifth Judicial District, First Branch.
The confirmed title was further evidenced by the tax declaration issued in June 1973 under Tax Declaration No. 9247.

In August 2009, the Malits filed a complaint for cancellation and declaration of nullity of Free Patent No. 035408-09-1197 and the Katibayan ng Orihinal na Titulo Blg. 14447 issued in the names of respondent spouses Nicasio Flores, Jr. and Perlita Flores.
Petitioner contended that the free patent and corresponding title were procured by respondents through fraud, arguing that the issuance was flawed not only procedurally—without proper investigation or adequate notice as required under Commonwealth Act No. 141—but also substantively since Lot No. 1298 had already been classified as private land following the 1959 decision.

The Regional Trial Court (RTC) of Guagua, Pampanga, Branch 52 rendered a decision on October 29, 2015, in favor of the Malits.

The RTC declared Free Patent No. 035408-09-1197 and the corresponding title null and void on the ground that fraud had vitiated respondents’ application, and that the issuance was improper given the existing tenancy relationship and the confirmed private title of the Malits.

On August 22, 2017, the Court of Appeals (CA) reversed the RTC’s decision, holding that the Malits failed to prove by clear and convincing evidence the presence of fraud in the procurement of the free patent.

The CA ruled that the presumption of regularity in the issuance of the title under the Land Registration Act was sustained.
It further suggested that the delayed assertion of the Malits' rights, by not having the land registered under the Torrens System within a reasonable period, amounted to an abandonment or waiver of their claim.

Petitioner elevated the issue to the Supreme Court through a Petition for Review on Certiorari, contesting the CA’s finding and asserting that neither laches nor the statute of limitations applies to adjudications in land registration cases.

Respondents maintained that the free patent was valid as they had been in continuous, uninterrupted, open, and adverse possession in the concept of owner since 1944, although their possession was later challenged by the established tenancy relationship.
Documentary evidence showed that taxes on the land were paid only after the issuance of the free patent, suggesting that respondents did not meet the requisites for an application under public land laws (Commonwealth Act No. 141).
The historical confirmation of the Malits’ title—through the 1959 decision and subsequent issuance of an order for the issuance of a decree—was central to establishing that Lot No. 1298 had already transited from public alienable land to a privately held property.

Whether the Court of Appeals erred in ruling that the Malits failed to prove overriding fraud in the procurement of the free patent application by the respondents.

Petitioner argued that the procedural irregularities and the absence of a proper investigation as mandated by Commonwealth Act No. 141 amount to fraud in the issuance process.

Whether the Court of Appeals improperly applied the doctrine of laches against the Malits’ claim.

The contention was that claims in land registration cases, particularly those establishing ownership through a final judicial decree, should not be subject to the infirmities of laches or statutory prescription.
The petitioner further asserted that the finality of the 1959 decision, which confirmed the land as private, nullified any adverse claims based on delayed registration under the Torrens System.