Title
Davao Grains Inc. vs. Intermediate Appellate Court
Case
G.R. No. 78209
Decision Date
Mar 31, 1989
A homestead land, titled through cadastral proceedings, was sold to innocent purchasers; SC upheld sales, ruling homestead restrictions unenforceable against buyers.
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Case Summary (G.R. No. 78209)

Approval of Homestead Application and Land Segregation

  • The approval of a homestead application results in the segregation of the land from the public domain.
  • This approval divests the Bureau of Lands of its control and possession over the land.
  • The abandonment of the land by the original occupant does not alter its status as a homestead.

Possession and Rights to Land

  • A possessor who meets all necessary requirements for a homestead grant is deemed to have acquired a right to a grant by operation of law.
  • The absence of an approved homestead application does not negate the conclusion that the land is a homestead.
  • Actual possession of the land, openly and continuously, can establish rights to a certificate of title under relevant laws.

Registration as the Operative Act

  • The act of registration is essential for the conveyance of land and serves as notice to the public regarding the land's status.
  • A deed or grant from the government does not take effect as a conveyance until registered.
  • Without registration, a vendee is not bound by restrictions related to the purchase of a homestead unless they have prior knowledge of its status.

Reliance on Certificate of Title

  • Third parties dealing with registered lands can rely on the correctness of the certificate of title.
  • The law protects the rights of innocent purchasers who acquire property based on the validity of the title.
  • Courts cannot disregard the rights of individuals who have relied on the certificate of title when determining property ownership.

Case Background and Legal Proceedings

  • The land in question was originally applied for as a homestead and was later occupied and developed by private respondents.
  • Cadastral proceedings were initiated, leading to the issuance of a certificate of title in favor of the private respondents.
  • Subsequent sales of the property to petitioners were contested by the private respondents, who sought to repurchase the land as a homestead.

Court Decisions and Appeals

  • The trial court dismissed the private respondents' initial complaint for repurchase, leading to a final and executory judgment.
  • A later action for annulment of the sales was filed, resulting in a decision that declared the sales null and void based on the homestead status.
  • The appell...continue reading

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