G.R. No. 158597 - Prieto vs. Court of Appeals

Petitioners – the heirs of Simplicio Santiago, represented by Angelita S. Castro, who claim ownership over part of Lot No. 2344.
Respondents – the heirs of Mariano E. Santiago, asserting ownership over other portions of the same lot.

The property in controversy is Lot No. 2344, Cad-349, a 574-square-meter parcel located in Poblacion, Angat, Bulacan.
The lot originally belonged to Vicente Santiago and Magdalena Sanchez and was passed on to their children, including Pablo and Marta, leading to divergent claims among subsequent generations.

Simplicio Santiago, a son in the Santiago clan, acquired Lot 2344 by purchase from his father Pablo and his brother Guillermo.
Upon retiring from government service in 1968, Simplicio constructed a house on the lot.
Prior to his death on May 6, 1983, Simplicio applied for and was granted a free patent, resulting in the issuance of Original Certificate of Title (OCT) No. P-10878 on September 26, 1980 covering the entire lot.
Despite the free patent, evidence shows that the lot was already in open, continuous, exclusive, and notorious possession by family members, backed by tax declarations and long-standing occupancy.

At a later stage, Mariano Santiago, acting with apparent bad faith, constructed a house on a portion of the lot (designated as Lot 2344-C) and refused to vacate despite demands.
A subdivision of Lot 2344 was alleged:

Lot 2344-A, reportedly measuring 168 square meters, which Mariano and his sister Belen S. Marcelo claimed to have purchased from Simplicio Santiago in 1972.
Lot 2344-B, measuring 349 square meters, claimed by petitioners.
Lot 2344-C, measuring 57 square meters, on which Mariano’s house stands and which was inherited from their grandmother Marta Santiago.

Witness testimony, including that of a twenty-three-year-old Nestor Santiago, affirmed that Mariano’s house on Lot 2344-C had existed since his youth, suggesting long possession predating the dispute.

On April 3, 1984, petitioners filed an accion publiciana with damages to recover possession and assert title over Lot 2344.
In August 1991, the trial court ruled in favor of the petitioners by declaring the petitioners as owners of the property under OCT No. P-10878 and ordering Mariano to remove his house from the disputed 57-square-meter portion.
Mariano’s subsequent death in July 1993 led to his substitution by his heirs.
On December 3, 1999, the Court of Appeals reversed the trial court’s decision, declaring that the free patent and OCT were null and void because they were issued over a private land, not subject to the free patent provisions applicable only to public domain lands.

The free patent and OCT issued in the name of Simplicio Santiago.
The subdivision plan and tax declarations which traced the continuous possession of the Santiago clan over the property.
Notarized deed of sale evidencing the purchase of Lot 2344-A by Mariano Santiago and Belen S. Marcelo.

Witness testimonies from family members and long-time neighbors corroborated the longstanding, adverse possession and occupancy of parts of Lot 2344.

The central factual controversy revolves around the validity of the free patent and OCT issued by the Director of Lands over a parcel of private land.
The case raises the issue of whether free patent applications under the Public Land Act, designed for disposable lands of the public domain, can affect lands already in private ownership through possession or registered possessory information.

Whether the free patent and the certificate of title (OCT No. P-10878) issued in favor of Simplicio Santiago over Lot No. 2344 are valid.
Whether respondents’ claim of ownership over Lots 2344-A and 2344-C is sufficiently supported by the evidence, including long, continuous, and notorious possession.
Whether the petitioners’ challenge constitutes a collateral attack on a Torrens title and is barred by prescription, or if the action to annul the title falls within the exception provided for quieting title claims by possessors.
Whether the Director of Lands had the authority to issue a free patent over a property that had ceased to be part of the public domain and was already privately owned.