G.R. No. L-43679 - Spouses Azarcon vs. Vallarta

The litigants are the plaintiffs-appellants, Leonardo N. Azarcon and Rosa Cajucom-Azarcon (collectively, the Azarcons), and the defendants-appellees, Leopoldo Vallarta, Luis T. Vallarta, Julian T. Vallarta, Corazon Vallarta, and Emilio Lorenzo (collectively, the Vallartas).
The dispute centers on a parcel of irrigated riceland of approximately ten hectares located at Sitio Bagnoy, San Juan de Dios, Aliaga, Nueva Ecija.
The land was originally owned by Dr. Jose V. Cajucom, father of Rosa Cajucom-Azarcon.

Original Certificate of Title No. P-2815 in the name of the Azarcons.
Original Certificate of Title No. 0-3093 (later subdivided into several Transfer Certificates of Title) in the name of the Vallartas.

The existence of these conflicting titles set the stage for the ensuing litigation over which title was valid and superior.

On March 14, 1932, evidence shows that Dr. Jose V. Cajucom sold a nine-hectare agricultural parcel (situated within the disputed land) to Julian Vallarta Sr. and his wife, Francisca Trinidad, establishing the Vallarta claim.
A resurvey on September 6, 1959 revealed that the parcel, initially believed to be nine hectares, was actually nineteen hectares.
Consequently, on October 7, 1960, Dr. Cajucom executed a "Waiver and Quitclaim" for the excess ten hectares (now in dispute) to Julian Vallarta Sr. in exchange for P5,000.00.
Prior to the waiver, on October 20, 1959, Dr. Cajucom had executed a "Deed of Absolute Sale" of the same land in favor of the Azarcons for P20,000.00, describing the land as unregistered and as his "paraphernal" property inherited from his father.

In 1961, Rosa Cajucom-Azarcon filed a Free Patent Application over the disputed property, supported by affidavits from several witnesses attesting to the prior occupation and cultivation of the land since 1934.
The Free Patent Application was approved on February 26, 1961, resulting in the issuance of Free Patent Entry No. 18504.
On May 8, 1961, the Register of Deeds of Nueva Ecija issued OCT No. P-2815 in the name of the Azarcons.
Separately, the Vallarta heirs initiated voluntary registration proceedings in 1965 (LRC Rec. No. N-26618), which culminated in a decision on April 18, 1966, favoring their claim and resulting in the issuance of OCT No. 0-3093 on July 18, 1966.
The disputed property was later subdivided, and the respective Vallarta heirs subsequently secured individual Transfer Certificates, accompanied by Tax Declarations and payments of real estate taxes and irrigation fees.

Following non-compliance with earlier letters of demand by the Azarcons (dated March 5 and 22, 1968), they sought judicial relief by filing a petition on March 18, 1969 for the cancellation of the Vallarta titles.
The petition was dismissed by the Court of First Instance on the ground that the registration proceedings resulting in the issuance of the Vallarta title had become final and executory.
Unsatisfied with the dismissal, the Azarcons then filed a Complaint for Cancellation and Annulment of Titles on May 6, 1968, bringing into issue the validity, superiority, and indefeasibility of both titles.
The trial court rendered a decision on December 27, 1969 in favor of the Vallartas, declaring the free patent (and related OCT) of the Azarcons null and void.

Sale documents indicating the transfer of land to both sets of parties.
Survey plans (Psu-171661 and psu 177178) detailing the area and delineation of the disputed land.
The Waiver and Quitclaim executed on October 7, 1960 and the Deed of Absolute Sale executed on October 20, 1959.
Affidavits and tax declarations used to support the claim of possession and payment records.

The land was private property of Dr. Jose V. Cajucom and not part of the public domain.
The Vallartas had uninterrupted possession from as early as March 14, 1932, whereas the Azarcons’ claim of continuous possession only commenced with their later attempt to reclaim possession in 1968.
The free patent issued to the Azarcons involved misrepresentations, particularly regarding the public or private status of the land.

Whether the free patent, which was based on misrepresentations about the land being part of the public domain, could validly confer title.
Whether Section 91 of Commonwealth Act No. 141, which mandates the cancellation of such patents when predicated on false material statements, applied in this case.

Which title should prevail between the Azarcons’ free patent (and OCT No. P-2815) and the Vallartas’ registered title (OCT No. 0-3093 and subsequent transfers)?
The consideration of continuous possession and earlier established evidence versus the timing of registration.

Whether the counterclaim presented by the Vallartas was a mandatory part of the proceedings rather than a collateral attack on the Azarcons’ title.
The implications of the counterclaim regarding the proper docketing and whether any procedural defect existed in its handling.