Facts:

The case at hand, Ernesto Balbin et al. vs. Pedro C. Medalla et al., was decided by the Supreme Court of the Philippines on October 30, 1981, and is summarized as a petition for certiorari challenging the decision of the Court of First Instance of Occidental Mindoro, Branch I. The private respondents, Pedro C. Medalla and Josefina Medalla, purchased a large parcel of agricultural land located in Sitios of Bacong, Tambunakan and Ibunan, Barrio Balansay, Mamburao. After the purchase on June 19, 1962, they filed an application for the registration of title for this land on June 14, 1963. They provided evidence of ownership through a Deed of Sale from the heirs of Juan Ladao, along with an Informacion Posesoria issued in Ladao's name, tax declarations, and receipts spanning from May 1904 to January 1962.

The petitioners, who oppose this application, are Ernesto Balbin, Jose Orina, Mauricio Narag, Rosa Sta. Maria Sytamco, Basilio Sytamco, Leocadio Sytamco, Amado V. Reyes, Lydia V

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Facts:

Acquisition and Registration of Lands by Private Respondents

• On June 19, 1962, private respondents purchased a large parcel of agricultural land in Sitios Bacong, Tambunakan, and Ibunan, Barrio Balansay, Mamburao, Occidental Mindoro from the heirs of Juan Ladao.
• On June 14, 1963, they filed an application for registration of title using:
• The Deed of Sale executed in their favor.
• An Informacion Posesoria issued in the name of Juan Ladao.
• Tax declarations and receipts spanning from May 26, 1904, to January 27, 1962.
• Evidence of continuous payment of land taxes and declaration for taxation purposes.

Issuance of Patents and Titles to Petitioners

• Petitioners obtained original Certificates of Title through either Homestead or Free Patent grants:
• Rosa Sta. Ma. Sytamco received OCT No. P-3088 under Homestead Patent No. HV-85975.
• Basilio Sytamco received OCT No. P-3089 under Homestead Patent No. HV-86191.
• Leocadio Sytamco received OCT No. P-3087 under Homestead Patent No. HV-85977.
• Lydia Reyes received OCT No. P-4010 under Homestead Patent No. HV-85978.
• Amado Reyes received OCT No. P-4011 under Homestead Patent No. HV-85976.
• Apolinario Reyes received OCT No. P-3084 under Homestead Patent No. HV-85974.
• Ernesto Balbin received OCT No. P-919 under Free Patent No. V-58633.
• Mauricio Narag received OCT No. P-4060 under Free Patent No. V-94632.
• Jose Orina received OCT No. P-920 under Free Patent No. V-58631.

Controversy and Opposition in Land Registration Proceedings

• Petitioners opposed the respondents’ application for registration on the ground that they had been previously issued titles.
• The land subject matter was identified as Lot Nos. 979, 980, 981, 982, 983, 984, 1013, 1016, and 1006, as shown in specific subdivision plans.
• During pre-trial, a stipulation of facts was agreed upon, including:
• Identification of the lots encompassed in plans Ap-10864 and Ap-10866.
• The opposition was based on the claim that the lots in respondents’ case were already titled in petitioners’ names.
• The basis of the private respondents’ claim was the possessory information title of Juan Ladao registered on May 25, 1895.

Claims and Assignments of Errors by Petitioners

• Petitioners contended that the respondent judge erred in upholding the validity of the possessory information title of Juan Ladao.
• They argued that:
• The possession of land by petitioners through the homestead or free patents was valid, and the subsequent possessory information title was flawed.
• The cause of action for reconveyance had prescribed.
• The private respondents lacked personality and capacity to institute the action since the lands were public at the time the patents and titles were issued.
• The lower court did not have jurisdiction over the private respondents’ cause of action.

The Controversial Issue on the Validity of the Possessory Information Title

• The central factual dispute involved whether the possessory information title registered on May 25, 1895, in the name of Juan Ladao was valid.
• Petitioners argued that registration was done 38 days beyond the one-year period (from April 17, 1894, to April 17, 1895) required by the Maura Law.
• The case analysis noted the distinction between the institution of the possessory information proceeding and the registration of the title, emphasizing that registration is a governmental act following the proper proceedings.

Prescription and Timeliness of the Reconveyance Action

• Petitioners maintained that an action for reconveyance arising from fraud should have been instituted within four years of the discovery of fraud.
• They argued that:
• With the issuance dates of the respective patents ranging from 1956 to 1959, the reconveyance action should have been filed by the latest on October 14, 1963.
• Respondents’ complaint for reconveyance and annulment of titles was filed on August 30, 1973, thereby lapsing the period prescribed by law.
• The argument was made that possession evidenced by the issuance of the Torrens titles rendered petitioners’ rights indefeasible, while the possessory information was subject to prescription.

Issue:

Validity of the Possessory Information Title

• Whether the possessory information title registered on May 25, 1895, in the name of Juan Ladao was valid despite its registration occurring beyond the one-year period provided by the Maura Law.
• Whether the required proceedings for instituting a possessory information title within the one-year period were properly followed, regardless of the actual registration date.

Timeliness of the Reconveyance Action

• Whether the action for reconveyance for recovery of lands should have been filed within the four-year limitation period after the discovery of the alleged fraud.
• Whether more than 14 years elapsed from the issuance of petitioners’ titles, thereby baring the reconveyance remedy by prescription.

Capacity and Standing of Private Respondents

• Whether private respondents, by virtue of having acquired a possessory information title and subsequent actions, had the requisite personality and capacity to institute the action for reconveyance.
• Whether the lands were considered public at the time of issuance of the patents, affecting the standing of the respondents.

Jurisdiction of the Lower Court

• Whether the respondent judge erred in asserting jurisdiction over the nature and cause of action raised by private respondents given the complexities of public versus private land ownership.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)