G.R. No. L-31083 - Francisco vs. Rodriguez

In 1932, plaintiff-appellant Ursula Francisco applied for the purchase of Lot No. 595, Cadastral No. 102 of the Davao Cadastre, covering 33.1185 hectares located in barrio Bunawan, Davao City.
Her application was rejected by the Director of Lands on the ground that she had “permitted herself to be a dummy” in the acquisition of the said land.
Despite the rejection, she continued in possession of the land.

In June 1940, Ursula Francisco conveyed 29.3298 hectares of the lot to her former lawyer, Julian Rodriguez.
Believing at the time that the document executed was an antichresis, she later discovered it was in fact a deed of absolute sale.
Consequently, she filed civil case 9-R in the Court of First Instance of Davao seeking the annulment of the deed.
The court declared the deed null and void, and the land was deemed Government property.

Following the annulment, the Bureau of Lands reinstated her sales application but ordered a stay on its execution.
Subsequently, Ursula Francisco filed Civil Case 268 against Julian Rodriguez (with defendant-intervenor Monina Rodriguez participating) seeking recovery of possession, monetary damages, and additional relief.
After trial, the lower court ruled that neither party was entitled to possession of the disputed property, leaving its disposition to the Department of Agriculture and Natural Resources.

Both parties appealed the Court’s decision, asserting different grounds including restoration of status ante litem motam and claims to fruits pendente lite, but their motions were denied.
The Secretary of Agriculture, after a full investigation by the Bureau of Lands, denied the claims of Julian Rodriguez and Monina Rodriguez over the 29.3298 hectares, declaring the land vacant and subject to public bidding.
The Office of the President affirmed the Secretary’s ruling, and later, the Director of Lands intervened in Civil Case 268 to dissolve the receivership after accounting was rendered by the receiver.

On October 31, 1962, the Court ruled in G.R. No. L-15605 that reversion is self-operative, meaning no independent action by the Government is necessary to effect the reversion of the property to the State.
The controversy centered on whether the reversion applied to the entire 33.1185-hectare Lot No. 595 or only to the 29.3298 hectares that had been sold and later annulled.
Subsequent proceedings involved motions by defendants and oppositors regarding possession, payment of fruits pendente lite, termination of the receivership, and challenges based on elapse of time since finality, all addressed by lower court orders culminating in the issuance of a writ of execution ordering the complete possession of the land by government representatives.

The primary issue presented is whether the reversion declared in the earlier decision (G.R. No. L-15605, October 31, 1962) applies to the whole Lot No. 595, encompassing 33.1185 hectares, or only to the 29.3298 hectares that were conveyed to Julian Rodriguez and subsequently annulled.

Whether the parties can claim possession and the fruits of the property pendente lite despite the annulment of the sale and the reversion of the land to the government.
The issue also considers if the reversion automatically extinguishes any claim to the parts of the property that had not been directly involved in the void transaction.

Whether the actions taken by Ursula Francisco—acting as a dummy and effectuating an unauthorized conveyance—result in the irreversible forfeiture of her claim over the entire property.
The applicability of Section 101 and Section 29 of Commonwealth Act No. 141 in determining the effect of the reversion on the rights of the parties.