Case Digest (G.R. No. L-30389)
Facts:
Pedro Lee Hong Hok, Simeon Lee Hong Hok, Rosita Lee Hong Hok and Leoncio Lee Hong Hok v. Aniano David, The Hon. Secretary of Agriculture and Natural Resources, The Director of Lands and Court of Appeals, G.R. No. L-30389, December 27, 1972, the Supreme Court En Banc, Fernando, J., writing for the Court.Petitioners sought to have Original Certificate of Title No. 510 (Torrens title) of respondent Aniano David declared null and void. They alleged ownership of the disputed parcel by accretion and filed a complaint in the trial court to annul David’s Torrens title. The trial court dismissed the complaint. Respondent Court of Appeals affirmed the dismissal.
The Court of Appeals found that the disputed lot was formed by reclamation (not by natural accretion) and that David acquired title through a miscellaneous sales application: an order of award by the Director of Lands dated June 18, 1958; issuance of Miscellaneous Sales Patent No. V-1209 by the Undersecretary of Agriculture and Natural Resources on August 26, 1959; and issuance of OCT No. 510 by the Register of Deeds of Naga City on October 21, 1959. The Stipulation of Facts showed petitioners did not oppose David’s sales application or the subsequent proceedings up to issuance of the patent.
The Court of Appeals held that the land retained its public character (having been formed by reclamation), that private parties cannot collaterally attack a patent-based title (only the government may seek cancellation), and that under Republic Act No. 496, particularly Section 38, any question of invalidity based on fraud must be raised within one year of issuance of the patent, after which the title...(Pro-only)
Issues:
- May private parties (non-governmental) maintain an action to annul a Torrens certificate of title issued pursuant to a government patent?
- Was the disputed parcel private land by accretion, as petitioners contend, or public land formed by reclamation and thus subject to disposition only by the State?
- Did the issuance of the sales patent and the subsequent registration render respondent David’s title indefeasible under Section 38 of Republic Act No. 496, barring petitions ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)