G.R. No. 62341 - Wee Sit vs. Amin

Republic of the Philippines, represented by the Regional Executive Director, Department of Environment and Natural Resources (DENR) - Region IV, Manila, as Petitioner, filed an action for cancellation of free patent, Original Certificate of Title (OCT) and reversion.
Amor Hachero and the Register of Deeds of Palawan, as Respondents, were the holders of Free Patent No. 045307-98-9384 and OCT No. E-18011 covering the subject land.

The subject land was Lot No. 1514, CAD-1150-D, located in Sagrada, Busuanga, Palawan, with an area of 3.1308 hectares (31,308 square meters).
Sometime in 1996, Hachero filed Free Patent Application No. 045307-969 before the Community Environment and Natural Resources Office (CENRO) of Palawan.
The Provincial Environment and Natural Resources Officer (PENRO) of Palawan approved the application based on findings that:

Hachero was a natural-born Filipino qualified to acquire public land through free patent;
The land applied for had been classified as alienable and disposable;
An investigation by Land Investigator/Inspector Sim A. Luto found occupation and cultivation by Hachero or predecessors since June 12, 1945 or earlier;
Notice of acquisition was published and no other person had a better right;
No adverse claim was pending before CENRO; and
The claim was complete and no obstacle to issuance of the patent existed.

Free Patent No. 045307-98-9384 was issued on October 15, 1998, and the land was registered under OCT No. E-18011 on May 7, 1999.

A CENRO inspection and verification in 2000 discovered that the subject land remained classified as timberland and thus not susceptible of private ownership under the Public Land Law.
The Inspection Report dated July 24, 2000, and the Verification dated July 17, 2000, prepared and signed by Sim Luto and Diosdado L. Ocampo, attested that the subject land fell within the timberland zone under Project No. 2A, L.C. Map No. 839, released December 9, 1929, and recommended cancellation of OCT No. E-18011.
The Republic also introduced maps prepared by NAMRIA showing the subject land within the unclassified public forest and beyond the alienable and disposable area.

On November 26, 2002, the Republic filed Civil Case No. 3726 for cancellation of Free Patent No. 045307-98-9384 and OCT No. E-18011 and for reversion.
Hachero was personally served but did not file a responsive pleading and was declared in default by the RTC; the Republic presented evidence ex parte through witness Diosdado Ocampo and offered documents including the application, orders of approval, the free patent, OCT, the Inspection Report, and the Verification.
On March 29, 2006, the Regional Trial Court, Branch 48, Puerto Princesa, Palawan, denied the Republic's action and refused cancellation and reversion, reasoning among others that:

The free patent and title were public documents presumed regular;
The CENRO officials who certified alienability originally had brought the land under the Torrens System and could not be doubted;
The Republic failed to show the L.C. Map No. 839 even though allegedly available at CENRO at the time of application;
The Inspection Report and Verification by Sim Luto and other CENRO officials were insufficient to defeat the patent and title.

The Verification lacked probative value because L.C. Map No. 839 (December 9, 1929) was not presented at trial;
The Inspection Report alone was insufficient to...(Subscriber-Only)

Whether the findings of fact of the RTC and the CA, which upheld the validity of Free Patent No. 045307-98-9384 and OCT No. E-18011, were conclusive and insulated from this Court's review.
Whether the July 2000 Inspection Report, Verification, and NAMRIA maps sufficed to prove that the subject land remained timberland and thus inalienable and non-disposable public domain.

Whether the presumption of regularity in favor of DENR personnel in performing official duties applied and, if so, whether it was rebutted.
Whether the State could seek cancellation and reversion of a previously issued patent and OCT on the ground of mistake or oversight absent fraud or misre...(Subscriber-Only)