Case Summary (G.R. No. 141296)
Relevant Background
The case originates from a complaint filed by the DENR for the reversion of Lot No. 2744, Cadastral 241, Orion Cadastre, located in Capunitan, Orion, Bataan. The lot, once owned by the deceased Agustin L. Angeles, was acquired through a free patent issued on February 24, 1964. A significant issue arose from the illegal postdating of a Deed of Absolute Sale for part of the property, executed after Angeles' death, which aimed to circumvent restrictions on the alienation of free patent lands within five years.
Procedural History
The Regional Trial Court (RTC) of Balanga, Bataan, dismissed the DENR’s complaint for reversion on September 7, 1999. The court determined that the state’s cause of action had prescribed since the complaint was filed more than thirty-four years after the issuance of the original title, and additionally ruled that the respondent Alvarez was an innocent purchaser for value.
Issues for Resolution
The primary issue addressed by the Supreme Court was whether the trial court erred in dismissing the petitioner's complaint on the ground of prescription, ultimately questioning if prescription runs against the State.
Court's Reasoning
The Court determined that the doctrine of laches and prescription does not apply to the State when it seeks to recover its properties that were obtained through fraudulent means. The Court criticized the RTC's reliance on the case of Esconde v. Barlongay, asserting that it was inapplicable to the current situation since that case dealt with an individual’s action for reconveyance, and not the State’s right to recover public land.
The Court affirmed that titles secured through fraud should not be immune to re-examination by the State, emphasizing that one who acquires property unlawfully should not benefit from their actions. Furthermore, contrary to the lower court's ruling, the Court reiterated that public
...continue readingCase Syllabus (G.R. No. 141296)
Case Background
- The case originated from a Petition for Review on Certiorari, aiming to overturn an Order issued by the Regional Trial Court (RTC) of Balanga, Bataan regarding Civil Case No. 6789.
- The RTC's Order, dated September 7, 1999, granted the respondents’ Motion to Dismiss the complaint for reversion based on the ground of prescription.
- The Order concluded with the dismissal of the complaint, stating it was meritorious.
Parties Involved
- Petitioner: Republic of the Philippines, represented by the Regional Executive Director, Region III, Department of Environment and Natural Resources (DENR).
- Respondents: Heirs of Agustin L. Angeles, Heirs of Carmen de Leon vda. de Angeles, Luz Gancayco Alvarez, and the Register of Deeds of Balanga, Bataan.
Factual Background
- On July 30, 1963, Agustin L. Angeles filed a Free Patent Application for Lot No. 2744, Cad. 241 in Orion, Bataan.
- Free Patent No. 265340 was issued on February 24, 1964, leading to the issuance of Original Certificate of Title No. 194 in Agustin's name.
- Agustin died on April 16, 1967.
- Before his death, Agustin transferred half of Lot No. 2744 to his sister, Emilia L. Angeles, through a Deed of Absolute Sale that was postdated January 5, 1970, violating a prohibition against alienation within five years of issuance.
- Emilia subsequently transferred her share to her daughte