Title
Davao Grains Inc. vs. Intermediate Appellate Court
Case
G.R. No. 78209
Decision Date
Mar 31, 1989
The dispute centers on the validity of land ownership and subsequent sales after private respondents assert the land remains subject to repurchase despite its cadastral award.
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Case Digest (G.R. No. 78209)

Facts:

  • The case involves Davao Grains Incorporated and Lapanday Agricultural and Development Corporation as petitioners against the Intermediate Appellate Court and private respondents Protacio Espina and Marcial Espina.
  • The Espina brothers settled on an abandoned parcel of land in Asuncion, Davao, after the liberation of the Philippines in 1945.
  • They filed a homestead application for the land on April 28, 1954, and paid the necessary fees.
  • While awaiting a patent, the government initiated cadastral proceedings, requiring all claimants to file answers.
  • The Espinas participated and received Decree No. N-130436 on June 19, 1970, leading to Original Certificate of Title (OCT) No. 0-2440.
  • On May 28, 1975, the Espinas sold the property to Lapanday for P24,520.40, resulting in the cancellation of OCT No. 0-2440 and the issuance of Transfer Certificate of Title (TCT) No. T-19171 in Lapanday's name.
  • Lapanday later sold the land to Davao Grains, which received TCT No. T-20083 on November 10, 1975.
  • On March 24, 1980, the Espinas filed an action to repurchase the property, claiming it was a homestead subject to repurchase under Commonwealth Act No. 141.
  • The trial court dismissed their complaint on January 15, 1982, ruling the land was not a homestead but a cadastral lot, a decision that became final as the Espinas did not appeal.
  • On August 19, 1983, the Espinas filed a new action for annulment of the sales, leading to a trial court ruling on February 14, 1984, that reinstated the original title in the Espinas' name.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioners, declaring the sales in favor of Lapanday and Davao Grains, Inc. valid, and...(Unlock)

Ratio:

  • The Court reasoned that the approval of a homestead application segregates the land from the public domain, granting the applicant rights over it.
  • The abandonment of the land by the original occupant does not alter its status as a homestead.
  • The Espinas cleared and developed the land and filed their homestead application, which was pending during the cadastral proceedings.
  • The issuance of a cadastral title does not negate the homestead character of the land, as the original homestead application...continue reading

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