Case Digest (G.R. No. 200973)
Facts:
In Republic of the Philippines v. Amor Hachero, G.R. No. 200973, decided on May 30, 2016 under the 1987 Constitution, the Republic of the Philippines, represented by the Regional Executive Director of the Department of Environment and Natural Resources (DENR) Region IV–Manila, sought cancellation of Free Patent No. 045307-98-9384 and Original Certificate of Title (OCT) No. E-18011 issued to Amor Hachero over Lot No. 1514, CAD-1150-D, a 3.1308-hectare tract in Sagrada, Busuanga, Palawan. In 1996, Hachero applied for a free patent, which PENRO Palawan approved, finding that the land was alienable and disposable, occupied and cultivated by Hachero since 1945, and that no adverse claims existed. Free Patent No. 045307-98-9384 was issued on October 15, 1998, and OCT No. E-18011 on May 7, 1999. A year later, a DENR task force discovered, via an inspection report (July 24, 2000) and verification (July 17, 2000) based on L.C. Map No. 839 (December 9, 1929) and NAMRIA maps, that the landCase Digest (G.R. No. 200973)
Facts:
- Antecedents
- In 1996, Amor Hachero filed Free Patent Application No. 045307-969 for Lot No. 1514, CAD-1150-D (3.1308 ha) in Sagrada, Busuanga, Palawan. The PENRO approved the application, finding the land alienable and Hachero qualified. Free Patent No. 045307-98-9384 was issued on October 15, 1998 and Original Certificate of Title (OCT) No. E-18011 on May 7, 1999.
- A 2000 CENRO inspection revealed the land remained classified as timberland under L.C. Map No. 839 (December 9, 1929), thus inalienable and non-disposable.
- Proceedings Below
- On November 26, 2002, the Republic (DENR-Region IV) filed for cancellation of the free patent and OCT and for reversion. Hachero defaulted; the RTC permitted ex parte evidence.
- The RTC (Branch 48, Puerto Princesa) denied cancellation on March 29, 2006. The Court of Appeals affirmed on July 4, 2011 (with resolution on March 6, 2012). The Republic then sought SC review via petition for certiorari.
Issues:
- Did the Court of Appeals gravely err in affirming the dismissal of the Republic’s petition to cancel the free patent and OCT and to revert the land?
- Can the presumption of regularity in DENR’s inspection reports and the State’s non-estoppel allow correction of a mistakenly granted patent over inalienable public land?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)