Case Summary (G.R. No. 50661)
Background
The case arose from a dispute involving claims over a parcel of land in Urbiztondo, Pangasinan, originally owned by Domingo Calzada. The land measures 3,018 square meters and has had various transactions linked to it. Domingo sold a 660-square-meter portion to Emilio Bandong in 1960, who allegedly later donated it to his son Pedro Bandong. In 1979, Pedro sold a larger portion, 1,320 square meters, to Marceliano Bandong. Upon Domingo's death in 1961, his heirs executed a Deed in 1984 to convey the remaining 2,358 square meters to the Spouses De Guzman. A cadastral survey in 1992 designated the portions as separate lots: Lot No. 3011 (claimed by the Bandongs) and Lot No. 3015 (claimed by the De Guzmans).
Application for Free Patent
In 1999, Marceliano applied for a free patent for a portion of the lot (Lot No. 3011), asserting continuous possession since 1979 and declaring it as public land not claimed by others. His application resulted in the issuance of Original Certificate of Title (OCT) No. P-41536 later that year. The De Guzmans learned of this application and filed a protest against it in 2002, asserting ownership of the disputed area based on their 1984 Deed. However, the Department of Environment and Natural Resources denied their protest, citing lack of jurisdiction and advising them to seek relief in court.
Regional Trial Court Decision
The Spouses De Guzman filed a complaint in the RTC, accusing the Spouses Bandong of fraud and misrepresentation. The RTC ruled in favor of the De Guzmans, stating that the increased area in Bandong’s title was due to a fault in the cadastral survey, ultimately deciding to cancel the OCT held by the Spouses Bandong and reaffirming the De Guzmans' ownership of the eastern portion of the land.
Court of Appeals Ruling
On appeal, the CA reversed the RTC's decision, arguing that the De Guzmans failed to present clear and convincing evidence of fraud concerning the issuance of the free patent to the Bandongs. The CA contended that mere possession by the De Guzmans did not negate the presumption of regularity afforded to the Notarized 1979 Deed, which indicated the Bandongs' legitimate ownership.
Petitioners' Claims and Court's Revaluation
The De Guzmans contended that their evidence demonstrated prior ownership and occupied the area before the Bandongs' free patent application. The Supreme Court acknowledged that the case required re-evaluation of the factual findings due to discrepancies between the RTC and CA's decisions. Importantly, it was noted that ownership claims arise from the need to establish prior ownership before the issuance of a free patent, which must reflect that the land could not be classified as public land.
Findings on Ownership and Possession
The Supreme Court found that both parties presented claims based on different deeds of sale, with the De Guzmans maintaining that the land in questio
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Case Overview
- This case involves a petition for review on certiorari filed by the Heirs of Spouses Corazon P. De Guzman and Fortunato De Guzman against the Decision and Resolution of the Court of Appeals that reversed the Decision of the Regional Trial Court (RTC) of San Carlos City, Pangasinan.
- The main issue revolves around the ownership of a parcel of unregistered land claimed by both parties, leading to a dispute about the validity of the free patent issued to the Spouses Bandong.
Background Facts
- Domingo Calzada was the original owner of a 3,018 square meter parcel of unregistered land in Barrio Angatel, Urbiztondo, Pangasinan.
- The land was partially sold by Domingo in 1960 to Emilio Bandong (660 sq. m.) and later transferred to Pedro Bandong, who sold a larger portion (1,320 sq. m.) to Marceliano Bandong in 1979.
- After Domingo's death in 1961, his heirs sold the remaining 2,358 sq. m. to the Spouses De Guzman in 1984.
- The cadastral survey in 1992 identified the claims of both parties as Lot Nos. 3011 and 3015, respectively.
Legal Proceedings
- Marceliano applied for a free patent in 1999, which was granted, leading to the issuance of Original Certificate of Title (OCT) No. P-41536 in favor of the Spouses Bandong.
- The Spouses De Guzman learned of this title and protested to the Department of Environment and Natural Resources - Com