G.R. No. L-14702 - Director of Lands vs. Jugado

On November 26, 1956, the Director of Lands filed a petition with the Court of First Instance of Negros Occidental seeking the annulment and cancellation of Homestead Patent No. V-28407.
The disputed parcel of land was identified as Lot No. 2644, a portion of Lot No. 2290 of the Himamaylan Cadastre in Negros Occidental.
The patent in question was issued on May 4, 1954 to respondent Lelita Jugado.
The petition alleged that the homestead patent was fraudulently issued in favor of Lelita Jugado because the land was already covered by a prior and subsisting approved homestead application of one Conrada Villavera.

On October 25, 1957, the Philippine National Bank, claiming to be a mortgagee in good faith concerning the property, moved to intervene in the proceedings and subsequently filed an answer.
The same intervenor later filed a motion to dismiss the petition on the ground that the petition was filed more than one year after the issuance of the patent and the corresponding certificate of title.
The intervenor asserted that the certificate of title had become perfect, absolute, and indefeasible beyond the one-year period as provided by law.

After the usual responsive pleadings, the trial court found merit in the intervenor’s motion and dismissed the petition for cancellation of the homestead patent.
The Director of Lands, as appellant, appealed the Order of Dismissal, contending that Section 38 of Act 496—limiting the period within which the validity of a certificate of title may be contested—is inapplicable in the case of homestead patents.

The appellant argued that the homestead patent should not be subject to the strict time limitations of Act 496.
The lower court’s dismissal was anchored on the established doctrine that once a public land patent is registered and the certificate of title issued, the land automatically comes under the protective operation of Act 496.
The case referenced precedents such as El Hogar Filipino v. Olviga, Aquino v. Director of Lands, and Manalo v. Lukban and Liwanag to solidify the notion that the land becomes private property and immune from later contestation after the one-year period.

Is the petition to cancel or annul Homestead Patent No. V-28407 maintainable even though it was filed more than one year after the issuance of the patent and certificate of title?
Does Section 38 of Act 496, which limits the period for contesting a certificate of title to one year from registration, apply to a homestead patent?
Can the Director of Lands, by itself, contest the validity of a homestead patent after the expiration of the one-year period?
Is there an alternative remedy under Public Land Law (Section 101 of Commonwealth Act No. 141) for recovering or reverting fraudulently awarded public lands, especially since the action was instituted by the Director of Lands and not by the proper state authority?