Case Digest (G.R. No. L-23712)
Facts:
Republic of the Philippines v. Ramona Ruiz, Domingo Pinto, Bonifacio Pinto, Victoria Pinto, Maria Pinto, et al., G.R. No. L-23712, April 29, 1968, the Supreme Court En Banc, Reyes, J.B.L., writing for the Court. The plaintiff-appellee is the Republic of the Philippines; the defendants-appellants are Ramona Ruiz and the heirs of Cayetano Pinto.The land in dispute was originally granted to Cayetano Pinto by Homestead Patent No. 22711 (issued June 13, 1933) corresponding to Original Certificate of Title No. 1-1600 (issued July 7, 1933). On May 28, 1937—about four years after the patent—Cayetano executed a deed of sale conveying a three-hectare portion to Jacobo Pinto for P500; that deed was never registered nor annotated on the certificate of title. Cayetano died in 1945.
On October 12, 1951, Cayetano’s widow, Ramona Ruiz, and the children executed an extra-judicial partition of the homestead; that partition was registered February 2, 1956 and resulted in Transfer Certificate of Title No. T-7196 in the names of the widow and heirs. On April 23, 1956 the owners mortgaged the parcel to the Philippine National Bank; the mortgage was annotated on T-7196.
Separately, on June 29, 1956 the widow Herminia Tinonas and the heirs of Jacobo (grantee of the 1937 deed) sued Ramona and the heirs in CFI, Isabela (Second Branch), Civil Case No. Br. II-90, seeking conveyance of the three-hectare portion; that court on August 5, 1958 declared the May 28, 1937 deed null and void for violating the Public Lands Law. The plaintiffs in Br. II-90 appealed to the Supreme Court; that appeal was dismissed November 6, 1959, making the Br. II-90 decision final.
Before the Br. II-90 appeal was perfected, the Republic on October 12, 1958 filed the present action in the Court of First Instance of Isabela (Civil Case No. Br. II-419) to cancel OCT No. 1-1600 and TCT No. T-7196 and to declare the land reverted to the State pursuant to the Public Land Law. The parties stipulated material facts, including the 1937 sale, the 1951 partition, the 1956 registration and mortgage, and the prior Br. II-90 litigation. The CFI held that Cayetano’s execution of the 1937 instrument within the prohibited five-year period after issuance of the patent violated Section 118 of Commonwealth Act No. 141, thereby annulling and canceling the patent and causing reversion to the State. Defendants appealed to the Supreme Court, principally arguing lack of cause of action because (a) the 1937 document was a mere unilateral promise or otherwise nonexistent under Article 140...(Pro-only)
Issues:
- Procedural: Can the appellants attack on appeal the character or existence of the May 28, 1937 deed when they admitted it in pleadings and the parties stipulated to it?
- Substantive: Does an alienation of a homestead within five years from issuance of the patent render the deed null and void and authorize reconveyance (reversion) of the homestead to the State under Commonwealth Act No. 141?
- Substantive: May reversion be ordered when only a portion of the homestead was alienated, and are the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)