Facts:

The case involves petitioners Protacio Banguilan, Narciso Banguilan, Elena B. Sanuco, Camilo Banguilan, Melita Guntayon, Nieves Balagasay, Estefania Banguilan, Ernestina B. Balabbo, Lorna B. Atuan, Juanita B. Ong, and Jose Banguilan, who sought the cancellation and annulment of free patent titles issued to respondents Brigida Manalo-Velasco, Pedro Manalo, Simeona M. Bunagan, and Jacinto Manalo, Jr. The events trace back to 1925 when Serapio Banguilan, predecessor to the petitioners, applied for a homestead over approximately 24 hectares of land located in Lanna, Tumauini, Isabela. Respondent Gregorio Manalo, predecessor to the respondents, protested against this application while simultaneously filing his own homestead application for the land. The Bureau of Lands ultimately favored the application of Serapio Banguilan, leading to the rejection of Gregorio Manalo’s claim.

In December 1979, the Director of Lands confirmed the ownership rights of Serapio Banguilan, which was uphel

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Facts:

Background and Predecessor Filings

• In 1925, Serapio Banguilan, predecessor-in-interest of the petitioners, cultivated approximately 24 hectares of public land located at Lanna, Tumauini, Isabela.
• Serapio Banguilan filed a homestead application (No. 108953, E-61170) with the then Bureau of Lands, asserting his right over the subject land.
• Simultaneously, Gregorio Manalo, predecessor-in-interest of the respondents, filed a protest with the Bureau of Lands under several docket numbers and also apparently filed a separate homestead application over the same property.
• Irene Baquiran intervened by filing both a protest-in-intervention against the petitioners’ application and a free patent application (No. 4-113) over the subject land.

Administrative and Judicial Determinations

• On December 10, 1979, the Director of Lands, through the Regional Director of Region 2, rejected Gregorio Manalo’s homestead application and Irene Baquiran’s free patent application, while giving "further due course" to Serapio Banguilan’s homestead application.
• On joint appeal by Gregorio Manalo and Irene Baquiran, the Office of the Secretary of the Department of Environment and Natural Resources (DENR) affirmed the Director’s decision on September 26, 1989, following an ocular inspection that established Serapio Banguilan’s actual and peaceful possession and cultivation of the land.

Later Developments and Issuance of Free Patents

• In December 1995, the Regional Office of the DENR in Tuguegarao, Cagayan issued free patent titles covering portions of the subject land in favor of respondents-heirs of Gregorio Manalo:
• OCT No. P-63110 in the name of Brigida Manalo-Velasco (50,411 square meters).
• OCT No. P-63108 in the name of Pedro Manalo (50,411 square meters).
• OCT No. P-63109 in the name of Simeona Manalo-Bunagan (50,411 square meters).
• OCT No. P-63111 in the name of Jacinto Manalo, Jr. (50,412 square meters).

Filing of Actions and Procedural Posture

• On March 13, 1996, respondents initiated a complaint for Quieting of Title and Damages before the RTC of Cabagan, Isabela.
• Subsequently, on September 30, 1997, petitioners filed a suit entitled "Reconveyance and Damages" (Civil Case No. 820) before the RTC of Cabagan.
• On April 1, 1998, the RTC rendered judgment in the respondents’ case, quieting title in their favor and ordering the petitioners to respect the issued certificates of title unless directly challenged.
• On April 5, 1999, petitioners amended their complaint, changing the cause of action from reconveyance to "Cancellation/Annulment of Titles and Damages," thereby targeting the free patent titles as unlawfully obtained despite prior adjudications in favor of Serapio Banguilan.

Court Decisions and Controversies

• The RTC, by its Order dated July 25, 2002, dismissed the petitioners’ amended complaint on the ground that they lacked the requisite legal personality, characterizing the action as essentially one for reversion rather than for cancellation or annulment of titles.
• On appeal, the Court of Appeals (Decision of September 30, 2004) affirmed the RTC ruling, emphasizing that:
• Since the subject property was public land before the issuance of free patents, petitioners had no standing to seek reconveyance;
• An action for reversion in cases of fraudulent issuance of Sales Patents or TCT’s must be filed by the State, typically through the Office of the Solicitor General; and
• The payment of real estate taxes by the petitioners was not sufficient to establish a claim of ownership.

Supreme Court’s Intervention

• Petitioners elevated the case via a Petition for Certiorari under Rule 65, contesting both the dismissal and the characterization of the cause of action as one for reversion.
• The Supreme Court reversed and set aside the Court of Appeals’ decision, clarifying that the petitioners’ action was properly cast as one for declaration of nullity of the free patents and certificates of title, based on allegations of prior ownership and fraudulent issuance contrary to established facts and administrative decisions.

Issue:

Characterization of the Cause of Action

• Whether the petitioners’ cause of action is properly for the cancellation/annulment of the free patent titles and certificates of title or should be considered an action for reversion.
• Whether the allegations in the Amended Complaint sufficiently assert a claim of prior ownership and fraudulent procurement of title, thereby distinguishing it from a mere reversion action.

Standing and Legal Personality

• Whether the petitioners, as successors-in-interest of Serapio Banguilan, have the legal standing to institute the suit against the respondents’ free patent titles, given the public land status of the subject property prior to the issuance of free patents.

Proper Remedy and Procedural Posture

• Whether the remedy available should be a direct proceeding for cancellation/annulment of titles in cases of fraudulent free patent issuance, rather than an action for reversion which is exclusively the prerogative of the State.
• Whether the petition for certiorari under Rule 65 is the appropriate procedural tool when strict adherence to technical rules might otherwise deprive petitioners of the opportunity to redress an apparent injustice.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)