Case Summary (G.R. No. 54191)
Transactions and Legal Action
On April 12, 1967, the petitioners conveyed ownership of these ricelands, along with an unregistered parcel, to the respondents for a purchase price of P18,000.00. Subsequently, on March 23, 1971, the petitioners initiated an action for legal redemption against the respondents, invoking Section 119 of Commonwealth Act No. 141, which allows vendors to redeem property within five years following its sale.
Trial Court Proceedings
The trial court, specifically the Court of First Instance of Camarines Sur, Branch VII, dismissed the petitioners' complaint due to insufficient proof. The ruling included an order for the cancelled titles and the deed of sale to be submitted for registration after the respondents paid appropriate fees.
Court of Appeals Ruling
The Court of Appeals modified the trial court's decision, dismissing the petitioners' complaint on the grounds of lack of cause of action. It ruled that the lands in question were private, thereby exceeding the authority of the Government to issue free patents. This decision emphasized that the petitioners had misrepresented the status of the lands, which had been privately owned and cultivated before their application for patents.
Findings on Land Ownership
The appellate court found substantial evidence supporting the private nature of the nine parcels, noting historical cultivation and persistent occupancy by various individuals. The court referenced that before the free patent applications, the lands were already recognized as private property. Additionally, it underscored that the Director of Lands lacked the authority to grant patents over lands that had transitioned to private ownership.
Legal Principles and Precedents
The appeal was dismissed on grounds established as conclusive by the Court of Appeals, reinforcing the notion that private ownership claims must be supported by evidence rather than assertions. Relevant legal precedents, including the case of De la Concha v. Magtira, were cited, which clarify that free patents cannot be issued over land that has ceased to be part of the public domain.
Modification of Appellate Decision
The Supreme Court affirmed the Court of Appeals' decision but modified it regarding the reversion of the lands to the Gov
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Case Information
- Court: Supreme Court of the Philippines
- Division: Second Division
- Citation: 263 Phil. 800
- G.R. No.: 54191
- Date of Decision: May 08, 1990
- Petitioners: Isaac Magistrado and Felisa Bagasina
- Respondents: Dorotea Esplana and Pelagia Oliva
Background of the Case
- The petitioners, Isaac Magistrado and Felisa Bagasina, were owners of nine parcels of ricelands situated in Iriga, Camarines Sur.
- The lands were acquired via free patent titles issued by the National Government, specifically through Original Certificates of Title (OCT Nos. 17485, 16532, 17691, 16734, 36405, 17090, 16443, 16643, and 16444).
- On April 12, 1967, the petitioners sold these lands, along with one unregistered riceland, to the respondents for a total price of P18,000.00.
Legal Proceedings
- On March 23, 1971, the petitioners filed for legal redemption against the respondents as per Section 119 of Commonwealth Act No. 141, which allows vendors to redeem the property within five years from the sale.
- The Court of First Instance of Camarines Sur dismissed the initial complaint due to insufficient proof.
Court of Appeals Decision
- The Court of Appeals modified the trial court’s decision, ruling:
- Dismissal of the complaint for lack of cause of action.
- Directing the return of the Original Certificates of Title to the Register of Deeds.
- Cancellation of the titles and reversion of the lands to the Government, but allowing for future registration applications.
- Ordering the petitioners to rei