Case Summary (G.R. No. 172720)
Factual Background
Eusebio Borromeo was granted Free Patent No. 586681 for agricultural land in San Francisco, Agusan del Sur. Prior to the expiration of the five-year prohibitory period, he sold this land to Eliseo Maltos. After Borromeo's death in 1991, his heirs sought to nullify the sale and reconvey the property, asserting it was conducted during a prohibitory period that makes such transactions void under the Public Land Act.
Legal Proceedings
The heirs of Eusebio Borromeo initiated a Complaint for Nullity of Title and Reconveyance against the Maltos spouses and the Register of Deeds. The trial court dismissed the complaint on the grounds of the heirs' failure to prove their standing as heirs and ruled that the sale was void as it violated the five-year prohibitory period. The trial court determined that no title passed from Eusebio Borromeo to Eliseo Maltos, engendering the potential for reversion to the state.
Appeal and Decisions
The heirs of Borromeo appealed, presenting further evidence of their status as legal heirs. The Court of Appeals reversed the trial court's decision, asserting that the property should revert to the heirs as the sale was void, but noted that action for reversion required initiation by the Office of the Solicitor General.
Key Legal Principles
Void Sale During Prohibitory Period: The five-year prohibition under Section 118 of the Public Land Act explicitly prevents the sale or encumbrance of land granted under free patents; any transaction violating this provision is null and void.
Reversion to Public Domain: Although the sale is deemed void, reversion of the land to the public domain is not automatic. Per Section 101 of the Public Land Act, only the Solicitor General may initiate an action for reversion.
Doctrine of In Par Delicto: This doctrine asserts that when two parties participate in an illegal contract, neither can seek legal relief from the courts. However, it does not apply when enforcing the principle would contravene public policy aimed at preserving property rights under the Public Land Act.
Court's Findings
The Supreme Court upheld the Court of Appeals' ruling but clarified that the reversion of the land is dependent upon an action initia
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Case Overview
- This case revolves around the validity of a sale of a parcel of agricultural land conducted during a five-year prohibitory period as stipulated by the Public Land Act.
- The core issue is the sale of land covered by Free Patent No. 586681, which was sold by Eusebio Borromeo to Eliseo Maltos well within the prohibitory period.
- The heirs of Eusebio Borromeo sought to nullify the sale and revert the property to the public domain.
Facts of the Case
- Issuance of Free Patent: Eusebio Borromeo was granted Free Patent No. 586681 on February 13, 1979, for land located in San Francisco, Agusan del Sur.
- Sale of Property: Eusebio Borromeo sold the land to Eliseo Maltos on June 15, 1983, within the five-year prohibitory period.
- Death of Eusebio Borromeo: Eusebio died on January 16, 1991. Before his death, he allegedly instructed his family to nullify the sale.
- Legal Action by Heirs: On June 23, 1993, Norberta Borromeo and her children filed a Complaint for Nullity of Title and Reconveyance against the Maltos spouses and the Register of Deeds.
Legal Arguments
- Maltos Spouses' Defense: They claimed they acted in good faith, asserting that the sale was valid as they relied on Borromeo's title. They contended that the proper party for reversion proceedings was the Office of the Solicitor General.
- Register of Deeds' Argument: The Register argued that the deed of sale was registered after the prohibitory period, making the registration ministerial.
- Heirs of Borromeo's Counter: They argued that good faith was irrelevant since the prohibitory period was evident on the title.
Trial Court's Findings
- Dismissal of Complaint: The Regional Trial Court dismissed the heirs' complaint, stating they failed to establish their status as heirs and that the sale was void due to the prohi