G.R. No. 218640 . November 29, 2021
Republic of the Philippines, represented by the Regional Executive Director of the Department of Environment and Natural Resources (DENR) for the Cordillera Administrative Region (CAR), Petitioner, vs. Rosita Sadca, Spouses Marcenio Lesino and Elizabeth Baguinay, Spouses Benito Bentadan and Helen Dimas, Spouses Romeo Fontanilla and Felomina Dagas, Respondents.

FACTS

Sadca Acay, a member of the Kankana-ey Tribe, applied for and was granted Free Patent No. (1-2) 120 over a 28,099-square meter parcel of land in Barrio Abatan, Mankayan, Benguet on August 29, 1975, resulting in the issuance of Original Certificate of Title No. P-788. Upon Acay’s death in 1986, the lot was allocated to his daughter, respondent Rosita Sadca, via extrajudicial settlement, and Transfer Certificate of Title No. T-22747 was issued in her name on June 24, 1987. Rosita later subdivided and sold portions of the lot to the other respondent spouses. On August 26, 2002, the Republic, through the DENR, filed a Complaint for cancellation and reversion, alleging the lot was within the inalienable Mount Data National Park and National Forest and that Acay committed fraud in his application by misrepresenting continuous possession. The Regional Trial Court dismissed the complaint on March 20, 2012, finding no proof of fraud. The Court of Appeals affirmed this dismissal on May 26, 2015, ruling that the Republic failed to substantiate its fraud claim and that Acay’s award was valid under the Public Land Act’s provisions for indigenous cultural communities. The Republic filed a Petition for Review, insisting Acay did not meet the possession requirement and the land was inalienable.

ISSUE

1. Whether the case falls within exceptions to a Rule 45 petition allowing the Supreme Court to entertain questions of fact.
2. Whether the Court of Appeals erred in upholding the validity of the free patent awarded to Sadca Acay.

RULING

1. The Petition does not fall within exceptions to a Rule 45 petition. An appeal under Rule 45 is limited to questions of law and is discretionary. The Republic failed to cite any established exception warranting a re-examination of factual findings, which are binding when affirmed by the Court of Appeals and supported by substantial evidence. Absent special and important reasons, the Supreme Court declined to disturb the lower courts’ factual conclusions.
2. The Court of Appeals did not err. The Supreme Court denied the Petition, affirming the lower courts’ rulings. The Republic failed to prove by clear and convincing evidence that Acay committed fraud in his free patent application. More importantly, Acay, as a member of an indigenous cultural community (Kankana-ey Tribe), was entitled to apply for confirmation of title under Section 48(c) of Commonwealth Act No. 141 (The Public Land Act), as amended by Republic Act No. 3872 . This provision allows members of such communities to obtain title to lands of the public domain, even if not officially classified as alienable and disposable, provided the land is suitable for agriculture and they have possessed it continuously for at least 30 years. The Court found Acay satisfied these requirements. The subsequent buyers were also purchasers in good faith, and the Republic’s action, filed 27 years after the patent was granted, was unreasonably delayed.