Case Digest (G.R. No. 218640)
Facts:
This case involves the Republic of the Philippines, represented by the Regional Executive Director of the Department of Environment and Natural Resources (DENR) for the Cordillera Administrative Region (CAR), as petitioner, versus respondents Rosita Sadca and three other couples who had bought parcels of land. The dispute centers on a 28,099-square meter parcel located in Barrio Abatan, Mankayan, Benguet, which was originally applied for free patent by Sadca Acay, a member of the Kankana-ey indigenous tribe, via Free Patent Application No. (1-2) 1296. On August 29, 1975, the Director of Lands issued Free Patent No. (1-2) 120 in Acay's favor, followed by the issuance of Original Certificate of Title No. P-788. After Acay’s death intestate on May 26, 1986, his heirs extrajudicially settled the properties, allocating the disputed lot to his daughter, Rosita Sadca. On June 24, 1987, the original title was cancelled and replaced by Transfer Certificate of Title No. T-22747 issue
Case Digest (G.R. No. 218640)
Facts:
- Background and Land Application
- Sadca Acay, a member of the Kankana-ey Tribe (an indigenous cultural community), applied for a free patent over a 28,099-square meter parcel of land in Barrio Abatan, Mankayan, Benguet, designated as Free Patent Application No. (1-2) 1296.
- On August 29, 1975, the Director of Lands issued Free Patent No. (1-2) 120 in favor of Acay, and subsequently, the Original Certificate of Title No. P-788 was issued to him.
- Acay died intestate on May 26, 1986; the heirs extrajudicially settled the properties and allocated the Barrio Abatan lot to Acay's daughter, Rosita Sadca.
- On June 24, 1987, Original Certificate of Title No. P-788 was cancelled and replaced with Transfer Certificate of Title No. T-22747 issued in Rosita’s name.
- On April 30, 1990, Rosita subdivided the lot into 13 parcels and sold them to Spouses Marcenio Lesino and Elizabeth Baguinay, Spouses Benito Bentadan and Helen Dimas, and Spouses Romeo Fontanilla and Felomina Dagas, with certificates of title duly issued to buyers.
- Legal Challenge by the Republic of the Philippines
- On August 26, 2002, the Republic filed a Complaint for cancellation of the free patent and original certificate of title and for the reversion of the Barrio Abatan lot, alleging the property lay within Mount Data National Park and National Forest, thus inalienable.
- The Republic alleged misrepresentations and fraud by Acay in his free patent application.
- On March 20, 2012, the Regional Trial Court (RTC), Branch 64 in Abatan, Buguias, Benguet, dismissed the complaint due to the Republic’s failure to prove fraud or irregularities in Acay’s application.
- The Republic appealed, but the Court of Appeals (CA) denied the appeal on May 26, 2015, affirming the RTC and highlighting that Acay complied with the possession requirements under Section 48(c) of Commonwealth Act No. 141 (The Public Land Act) as amended by Republic Act 3872.
- The CA held that the lot buyers were in good faith, noting the long lapse (27 years) before the challenge and undisturbed possession by Acay and Rosita.
- Petition to the Supreme Court
- The Republic filed a Petition for Review under Rule 45, arguing that Acay did not continuously occupy or cultivate the land and that the lot included a road right of way, thus not suitable for agriculture.
- Respondents countered that:
- Registration of inalienable land by indigenous cultural community members is allowed under The Public Land Act;
- Acay complied with the 30-year possession requirement;
- The application form of Acay was never presented into evidence by the Republic;
- The Republic failed to overcome the presumption of regularity in the issuance of titles by DENR;
- The complaint selectively targeted them and violated equal protection.
Issues:
- Whether the Supreme Court can entertain questions of fact in this petition, considering Rule 45 limitations.
- Whether the Court of Appeals erred in upholding the validity of Acay’s free patent award and the corresponding certificate of title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)