G.R. No. L-64753 April 26, 1989
PLACIDO MANALO and ARMANDO MANALO, petitioners, vs. HON. INTERMEDIATE APPELLATE COURT, SPOUSES GEMINIANO DE OCAMPO and AMPARO DE OCAMPO, and SPOUSES PEDRO SANTOS and CRISANTA SANTOS, respondents.

FACTS

Private respondents, spouses De Ocampo and Santos, co-owned two parcels of land in Mariveles, Bataan, covered by Transfer Certificates of Title (TCTs) derived from Sales Patents issued by the Director of Lands in 1972 and 1973. They filed an action in 1973 for the cancellation of the titles of petitioners Placido and Armando Manalo, alleging that the Manalos had secured Free Patents and corresponding Original Certificates of Title (OCTs) in 1971 through misrepresentation. The Manalos claimed possession since 1944, even though the land was part of a U.S. Military Reservation turned over to the Philippine Government only in 1965.
The petitioners argued that their Torrens titles were indefeasible after one year and that the private respondents lacked legal capacity to sue. They contended that only the Government, represented by the Director of Lands through the Solicitor General, could bring an action for cancellation since the land originated from the public domain. The trial court ruled for the private respondents and ordered the cancellation of the Manalos’ titles, a decision affirmed by the Intermediate Appellate Court.

ISSUE

The primary issue is whether private respondents have the legal personality to institute an action for the cancellation of the petitioners’ land titles, and whether the petitioners’ titles are valid.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court held that private respondents had the legal personality to file the cancellation suit. The lots in question ceased to be part of the public domain upon their certification as disposable on May 19, 1971, and the subsequent issuance of free patents. Consequently, the Director of Lands lost jurisdiction over them. As holders of titles based on patents issued after this declaration, the private respondents had a direct interest and could sue to challenge allegedly void titles acquired by others.
On the validity of the petitioners’ titles, the Court found them null and void. The land was part of a military reservation until 1965, making lawful settlement or possession impossible before that date. The Manalos’ claim of possession since 1944 was therefore legally untenable. Their free patent applications, filed in 1967, were invalid as the land was not yet surveyed or declared alienable at that time; the survey plans were approved only in 1971, with an annotation that the land became disposable on May 19, 1971. The fundamental requirement of possession since July 4, 1945, for a free patent was not satisfied. Since the petitioners’ titles were void ab initio, the subsequent issuance of sales patents to the private respondents by the Director of Lands was valid. The principle of indefeasibility of a Torrens title does not protect a title issued through fraud or in violation of law.