Case Digest (G.R. No. 186487)
Facts:
The case involves Rosito Bagunu (petitioner) and spouses Francisco Aggabao and Rosenda Acerit (respondents). The dispute centers around a parcel of unregistered land located in Caniogan, Sto. Tomas, Isabela, which was previously owned by Marcos Binag. The land underwent several transactions: it was first sold by Binag to Felicisimo Bautista, who then sold it to Atty. Samson Binag in 1959. Atty. Binag applied for a free patent over the land on December 12, 1961, and later sold it to the petitioner on November 24, 1987. The deed of sale indicated that the land sold to the petitioner was the same lot subject to Atty. Binag's pending free patent application.
On December 28, 1992, the respondents filed a protest against the petitioner's free patent application, claiming ownership based on deeds of extrajudicial settlement with sale executed in their favor by the heirs of Rafael Bautista. The Department of Environment and Natural Resources (DENR) conducted an ocular insp...
Case Digest (G.R. No. 186487)
Facts:
Background of the Land Dispute
The dispute arose from a protest filed by spouses Francisco Aggabao and Rosenda Acerit (respondents) against Rosito Bagunu’s (petitioner) free patent application over an unregistered parcel of land in Caniogan, Sto. Tomas, Isabela. The land was previously owned by Marcos Binag, sold to Felicisimo Bautista, then to Atty. Samson Binag, who applied for a free patent in 1961. In 1987, Atty. Binag sold the land to the petitioner, who continued the free patent application.
Identification of the Land
The deeds of sale and surveys identified the land as Lot 322. However, in 1992, the respondents protested, claiming ownership of Lot 322 based on deeds executed by the heirs of Rafael Bautista.
DENR Investigation and Findings
The DENR Regional Office found that the petitioner occupied and cultivated the disputed land, including the area claimed by the respondents. However, it ruled that the petitioner wrongfully included Lot 322 in his application, as it belonged to the respondents. The DENR ordered:
- The respondents to file a public land application for Lot 322.
- The petitioner’s application to exclude Lot 322.
- A relocation survey to determine the exact boundaries of Lots 258 and 322.
Court Proceedings
The petitioner appealed to the DENR Secretary, who affirmed the ruling, concluding that the petitioner actually acquired Lot 258, not Lot 322. The Court of Appeals (CA) also affirmed, citing the DENR’s primary jurisdiction over public lands.
Civil Case for Reformation of Instruments
Atty. Binag filed a civil case for reformation of the deeds of sale, claiming they erroneously identified the land as Lot 322 instead of Lot 258. The respondents intervened, seeking quieting of title and damages.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Jurisdiction of the DENR: The DENR has exclusive authority over public lands, including determining the identity of disputed lots. The petitioner’s acknowledgment of the land as public by filing a free patent application confirms this.
- Doctrine of Primary Jurisdiction: Courts must defer to administrative agencies in matters requiring specialized knowledge, such as land disputes. The DENR’s findings on the identity of Lots 258 and 322 are conclusive.
- Reformation of Contracts: While reformation of contracts falls under court jurisdiction, the RTC must suspend proceedings pending the DENR’s final determination of the land dispute.