Title
Aznar Brothers Realty Co. vs. Spouses Ybanez
Case
G.R. No. 161380
Decision Date
Apr 21, 2014
Aznar Brothers' prior registered purchase of Lot No. 18563 prevails over Spouses Ybañez' claim; free patent and title issued to Ybañez declared void.
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Case Digest (G.R. No. 161380)

Facts:

Background and Initial Transactions

  • March 21, 1964: Casimiro Ybañez, with his wife’s consent, sold a 17,575 sqm unregistered agricultural land to Aznar Brothers Realty Company for P2,500. The deed was registered under Act No. 3344.
  • February 17, 1967: Saturnino Tanuco sold a 15,760 sqm parcel of land to Aznar Brothers for P2,528. This sale was also registered under Act No. 3344. Angel Abellana confirmed this sale via an affidavit on April 11, 1967.
  • July 3, 1968: Casimiro Ybañez died intestate, leaving his wife, Maria Daclan, and their children as heirs.

Extrajudicial Settlement and Sale

  • August 29, 1977: The heirs of Casimiro executed an Extrajudicial Declaration of Heirs with Extrajudicial Settlement of Estate, dividing and selling Lot No. 18563 to Adriano Ybañez for P1,000.
  • June 21, 1978: Adriano sold Lot No. 18563 to Jose R. Ybañez for P60,000.

Free Patent and Title Issuance

  • January 15, 1979: Jose R. Ybañez applied for a free patent for Lot No. 18563, claiming it as public land.
  • July 20, 1979: Original Certificate of Title (OCT) No. 2150 was issued to Jose R. Ybañez.

Legal Dispute

  • May 26, 1989: Aznar Brothers filed a complaint in the RTC, seeking to nullify the extrajudicial settlement and deeds of sale, cancel OCT No. 2150, and declare ownership of Lot No. 18563. The RTC dismissed Aznar Brothers’ complaint, declaring the Spouses Ybañez as legal owners.
  • October 10, 2002: The Court of Appeals affirmed the RTC’s decision but deleted the awards of moral and exemplary damages, attorney’s fees, and litigation costs.

Issue:

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Ruling:

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Ratio:

  1. Constructive Notice: Registration of deeds under Act No. 3344 constitutes constructive notice to the whole world, including subsequent buyers. The Spouses Ybañez were bound by the prior sale to Aznar Brothers.
  2. Prescription and Laches: Actions to declare nullity of void titles are imprescriptible. Aznar Brothers’ claim was not barred by laches as it had registered the deeds and maintained its ownership rights.
  3. Invalidity of Free Patent: A free patent issued over private land is void. The government cannot dispose of land already in private ownership, rendering OCT No. 2150 invalid.

Conclusion:

The Supreme Court declared Aznar Brothers as the sole and exclusive owner of Lot No. 18563, canceled the free patent and OCT No. 2150 issued to Jose R. Ybañez, and ordered the Spouses Ybañez to pay the costs of suit. ###


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