Title
Angeles vs. Republic
Case
G.R. No. 166281
Decision Date
Oct 27, 2006
Juan Sanga's heirs contested fraudulent free patents issued to occupants, asserting ownership. The Supreme Court upheld the State's authority to cancel titles, affirmed the heirs' intervention, and declared the patents invalid, confirming Sanga's lawful ownership.
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Case Digest (G.R. No. 166281)

Facts:

Background and Ownership of the Property
In 1940, Juan Sanga acquired a parcel of land in Mayondon, Los Baños, Laguna, from his father, Damaso Sanga. He declared the lot under his name, paid realty taxes, and planted fruit-bearing trees. He also mortgaged the property to the Rural Bank of Los Baños.

Entry of Occupants
In January 1960, Jesus Angeles, Feliciano Villamayor, the spouses Montano Malana and Gloria Malana, and Anselmo Navales entered and occupied portions of the property, constructing huts and duck sheds. Sanga allowed them to stay after they promised to vacate once their applications for revocable permits with the Bureau of Lands were approved.

Legal Actions
In 1972, Sanga had the property surveyed and demanded the occupants vacate. When they refused, Sanga filed an accion reinvindicatoria (Civil Case No. B-541) against them, asserting ownership. The Director of Lands intervened.

Issuance of Free Patents and Titles
Unknown to Sanga, the occupants had portions of the property surveyed while the case was pending. They were granted free patents, and Original Certificates of Title (OCT) were issued to them in 1978. They later mortgaged the properties to the Development Bank of the Philippines (DBP).

RTC Decision
In 1982, the Regional Trial Court (RTC) ruled in favor of Sanga, ordering the occupants to vacate the property. The decision became final and executory as the defendants did not appeal.

Protest and Investigation
Sanga filed a protest with the Bureau of Lands to cancel the free patents and titles. The Bureau found irregularities in the issuance of the patents and recommended their cancellation.

Reversion Complaint
In 1987, the Republic of the Philippines, represented by the Director of Lands, filed complaints for the cancellation of the free patents and titles and the reversion of the properties to the public domain. Sanga’s heirs intervened, seeking quieting of title and damages.

Issue:

  1. Whether the State has the personality to file the case for cancellation of titles.
  2. Whether the heirs of Juan Sanga can intervene in the case.
  3. Whether the properties covered by the titles issued to Angeles and Malana are the same as those involved in Civil Case No. B-541.
  4. Whether the titles issued to Angeles and Malana are valid.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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