G.R. No. 131667 - Heirs of Alcaraz vs. Republic

Julian Alcaraz, the possessor and actual occupant of a parcel of land in Barangay Bancal, Meycauayan, Bulacan, died on 13 April 1924.
His three children—Carlos, Timotea, and Igmedio, all bearing the surname Alcaraz—succeeded in the possession and occupation of the land by informally partitioning it into three clusters corresponding to each heir:

On 2 February 1974, Maria Paz Alcaraz-Gomez, representing the heirs of Carlos Alcaraz, filed Free Patent Application No. (III-6) 933, Entry No. 000705 with the Bureau of Lands, District Land Office No. III-6 in Tabang, Guiguinto, Bulacan.
Following an investigation and ocular inspection conducted by Geodetic Engineer Luis E. Balicanta and verification by District Land Officer Jesus B. Toledo, an Order of Approval was issued on 22 April 1974.
The Register of Deeds issued the Original Certificate of Title (OCT) No. 1887 on 7 May 1974 in the name of the heirs of Carlos Alcaraz covering the entire parcel of land.

Shortly after the issuance of the free patent and OCT, the heirs of Timotea (represented by Benito Dayor and his children) and those of Igmedio (represented by Adela Alcaraz-Evea) filed a formal protest in the same District Land Office.
The protest was later amended, assailing the validity of the free patent and OCT on allegations of fraudulent acts and misrepresentation.
A land investigator’s report recommended the recall and nullification of Free Patent No. (III-6) 000705 and the restoration of the rights of the protestants, including granting them preferential rights for registration.

On 30 July 1987, the Republic of the Philippines, represented by the Solicitor General, filed a complaint for annulment and cancellation of the free patent and OCT against the heirs of Carlos Alcaraz in the Regional Trial Court of Malolos, Bulacan.
The heirs of Carlos Alcaraz denied the allegations, maintaining their compliance with the requirements for the issuance of the free patent.
On 21 January 1988, the heirs of Timotea and Igmedio intervened and filed a complaint-in-intervention, asserting their co-ownership of the land with the heirs of Carlos Alcaraz based on the original partition.
After due hearings, on 9 October 1991, the trial court declared:

The free patent and OCT issued in the name of the heirs of Carlos Alcaraz as null and void ab initio.
The intervenors (heirs of Timotea and Igmedio) were recognized as co-owners, with the land to be partitioned into three separate lots.
Various administrative orders were issued regarding cancellation of tax declarations and subdivision of the land, alongside costs and attorney’s fees.

Dissatisfied with the trial court’s decision, the petitioners (heirs of Carlos Alcaraz) filed an appeal, docketed as CA-G.R. CV No. 35570.
On 18 March 1997, the Court of Appeals affirmed with modifications:

It upheld the nullity of the free patent and OCT by declaring them void ab initio.
It set aside parts of the trial court’s ordering on partition and substituted a new disposition ordering the reversion of the land to the public domain.

Subsequent motions for reconsideration filed by all parties were denied in a resolution dated 27 November 1997.

Fraud and misrepresentation were involved in the free patent application.
The free patent and corresponding OCT were legally and validly issued despite the alleged fraud.
The issued OCT had become indefeasible after one year.
The actions of the private respondents (representing other heirs) amounted to a collateral attack on the OCT.
The trial court improperly converted an original action for reversion into an action for reconveyance, settlement of estate, and partition.
The appellate court exceeded its authority by modifying the trial court’s decision regarding the reversion of land even though neither the Republic nor the private respondents appealed the trial court decision.

Whether fraud or misrepresentation was committed by the petitioners in their free patent application pursuant to Section 91 of Commonwealth Act No. 141, as amended.

Did the omission regarding the occupation of the land by the heirs of Timotea and Igmedio constitute fraud?

Whether Free Patent No. (III-6) 000705 and Original Certificate of Title No. P-1887 were legally and validly issued and registered in the name of the petitioners.

Can the issuance be vindicated despite the allegations of concealment of material facts?

Whether the Original Certificate of Title had become indefeasible and conclusive of the petitioners’ title over the land.

Does the lapse of one year render the title immune from subsequent claims or actions?

Whether the action taken by the private respondents constitutes an impermissible collateral attack on the OCT.

Is the defense that a Torrens title cannot be collaterally attacked applicable in this context?

Whether the trial court improperly converted the original action for reversion filed by the respondent Republic into a suite for reconveyance, settlement of the estate of deceased persons, and partition.

Whether the Court of Appeals had the power to modify the trial court’s decision by ordering the reversion of the land to the public domain, despite the fact that neither the Republic nor the private respondents appealed the trial court ruling.