Mabuhay Development Company v.

Ronquillo, DBP
GR No: L24705; April 29, 1971
Facts:
Due to the absence of fixed boundaries of a land then known as Hacienda Dizon, it became
subject to several cases filed by Segundo Dizon. To which a commission of three surveyors were
appointed to relocate the lines of the Hacienda. The surveyors reported that it was impracticable and
well-nigh impossible to re­locate the hacienda. A resurvey was undertaken by Wenceslao Santiago, who at
that time was already a private land surveyor, and a plan was prepared by him. The resurvey of Santiago
showed an area of 683.7638 hectares or an excess of a mere 2,899 square meters over the area stated in
the title of Tavera. Dizon then filed a registration case. Subsequently, Segundo Dizon was informed by a
public land surveyor named Gatchalian that the resurvey of Santiago did not include certain portions of
the hacienda. Upon this information, an additional survey was made by Gatchalian and another plan was
prepared and the said survey and plan of Gatchalian showed an excess of about 34 hectares over the
original area of the hacienda. Dizon then Amended his petition. The petitions were then approved. On
May of 1944 the said land was sold to Mabuhay Rubber Corp and TCTs were issued in it’s name. Later,
the property was conveyed to the herein plaintiff, the Mabuhay Development Com­pany, and T.C.T. 16858
and 16859 were issued in its name. Originally, during the time of Tavera, the hacienda was a single mass
of land. After the cadastral survey of Tarlac in 1933, said mass was divided into 17 lots which are now
parti­cularly described in the plaintiff's titles. Lots 6339, 6387 and 6554, appear to be subject to the
existing patents of herein respondents. On November 9, 1954, plaintiff decided to disentangle the maze
concerning its land by fil­ing a complaint with the Court of First Instance of Tarlac. The court then ruled
that the Court of First Instance of Tarlac, acting as a cadastral court, was without power and acted without
jurisdiction, when, in its decision of October 12, 1938, it virtually ordered the registra­tion of the
additional area of 79 hectares in favor of Segundo Dizon. The CA on appeal then ruled that to quiet the
titles over the disputed lots, the Re­gister of Deeds of Tarlac is hereby ordered to cancel plaintiff's titles
over lots 6339, 6554 and 6387 insofar as they affect the defendants' titles. On equitable considera­tions,
no pronouncement as to costs in this instance is made.

Issue:
Was the decision of the CA correct in ordering the cancellation of the appellant titles over lots 6339, 6554
and 6387?

Ruling:
Yes, In Manalo vs. Lukban, et al. It was held that land granted by the Government to a private individual
who applied for it as a homestead, is considered no longer registerable within the meaning of the Land
Registration Act after the issuance of the homestead patent and the original certificate of title issued in
accordance therewith. In Pamintuan vs. San Agustin et al., as well as in El Hogar Filipino vs. Olviga. The
Supreme Court likewise held that in a cadastral proceeding the Court has no jurisdiction to decree again
the registration of land already decreed and registered in an earlier registration case, and that the second
decree entered for the same land is null and void. The ruling of the court of appeals was affirmed.
 Republic v. Augusto Mina
GR No: L60685; June 29, 1982
Facts:
This is a Petition to review the order of the Court of First Instance of Bulacan, Branch III in
Valenzuela, dated December 29, 1977, dismissing the complaint instituted by the plaintiff to
declare null and void Free Patent No. 467702 and Original Certificate of Title No. P-1382 issued
in the name of defendant Augusto Mina. Defendant Augusto Mina filed a motion to dismiss
stating among others that inasmuch as the free patent was issued to him on February 109, 1975,
plaintiff is now barred by the statute of limitation from asking for reversion; that plaintiff has no
more cause of action against him for the reason that the property had already been sold to
spouses Narciso del Rosario and Teresita Zuniga on February 11, 1976, that is six (6) years after
the original issuance of the title. The Court a quo granted the motion to dismiss in an Order dated
December 29, 1977, stating that "the title of the defendant Augusto Mina has become
inconvertible and indefeasible after the one year period." The allegations in the complaint that
neither defendant Augusto Mina nor his predecessor-in-interest had ever occupied or worked in
subject property, and that Mina's free patent application had been fraudulently obtained, are
indicative of fraud in the filing of the application and obtaining title to the land, if proven, would
override the order of the trial court dismissing the case without hearing.

Issue:
Can a certificate of title rendered void be cancelled?

Ruling:
A certificate of title that is void may be ordered canceled. And, a title will be considered void if
it is procured through fraud, as when a person applies for registration of the land on the claim
that he has been occupying and cultivating it. In the case of disposable public lands, failure on
the part of the grantee to comply with the conditions imposed by law is a ground for holding
such title void. (Director of Lands vs. CA, 17 SCRA 71). The lapse of the one (1) year period
within which a decree of title may be reopened for fraud would not prevent the cancellation
thereof for the hold that a little may become in defeasible by registration, even if such title had
been secured through fraud or in violation of the law would be the height of absurdity.
Registration should not be a shield of fraud in securing title (Republic vs. Animas, 56 SCRA
499).
 SPOUSES FRANCISCO LAHORA and TORIBIA MORALIZON
v.
EMILIO DAYANGHIRANG, JR., and THE DIRECTOR OF LANDS
G.R. No. L-28565; January 30, 1971
Facts:
The spouses Francisco Lahora and Toribia Moralizon brought the present appeal to this Court
from the order of the Court of First Instance of Davao (in Land Reg. Case No. N-86), dismissing
their petition with respect to Lot No. 2228 on the ground of previous registration, said appellants
claiming that the question of the validity of a certificate of title based on a patent allegedly
obtained by fraud can be raised by them in a land registration proceeding, contrary to the ruling
of the court a quo. Petition was opposed by the appellants, who alleged that lands belonging to
him and his wife were included in the application for registration, mentioning specifically Lot
No. 2228 which was said to be already covered by Original Certificate of Title No. P-6055 in the
name of oppositor's wife. The Director of Lands also filed an opposition to the petition,
contending that the applicants or their predecessors-in-interest never had sufficient title over the
parcels of land sought to be registered, nor have they been in open, continuous, and notorious
possession thereof for at least 30 years.On 14 June 1967, counsel for the private opposition filed
a motion for correction of the number of the certificate of title covering Lot No. 2228,
erroneously referred to as OCT No. P-6055, when it should properly be OCT No. P-6053. It is
likewise prayed in the same motion that the petition be dismissed insofar as it includes Lot No.
2228, for the reason that said lot was already registered and titled in the name of the oppositor's
wife as of 21 June 1956. In its order of 18 June 1967, which was amended on 29 June 1967, the
court granted the opposition's motion and directed the dismissal of the petition as regards Lot
No. 2228, on the ground that it having been previously registered and titled, said parcel of land
can no longer be the subject of adjudication in another proceeding. Hence, this appeal by the
petitioners.

Issue:
Was the Court correct in ruling that the land, having been previously registered and titled, said
parcel of land can no longer be the subject of adjudication in another proceeding.

Ruling:
In the present case, Lot No. 2228 was registered and titled in the name of the oppositors' wife as
of 21 June 1956, nine (9) years earlier. Clearly, appellant's' petition for registration of the same
parcel of land on 26 November 1965, on the ground that the first certificate of title (OCT No.
P-6053) covering the said property is a nullity, and can no longer prosper. Orderly administration
of justice precludes that Lot 2228, of the Manay Cadastre, should be the subject of two
registration proceedings. Having become registered land under Act 496, for all legal purposes, by
the issuance of the public land patent and the recording thereof, further registration of the same
would lead to the obviously undesirable result of two certificates of title being issued for the
same piece of land, even if both certificates should be in the name of the same person. And if
they were to be issued to different persons, the indefeasibility of the first title, which is the most
valued characteristic of Torrens titles, would be torn away. For this reason, this Court has ruled in
Pamintuan vs. San Agustin, 43 Phil. 558, that in a cadastral case the court has no jurisdiction to
decree again the registration of land already decreed in an earlier case; and that a second decree
for the same land would be null and void. The order was then affirmed.
 TEODORO URQUIAGA and MARIA AGUIRRE
v.
THE COURT OF APPEALS, VICENTE CASES and ANITA CRISOSTOMO
G.R. No. 12783; January 22, 1999
Facts:
On 14 August 1985 respondent spouses moved for the issuance of a temporary restraining order
against petitioner Urquiaga on the ground that he constructed a dike on the subject property. An
ocular inspection by the trial court confirmed their allegation. Consequently, on 28 August 1985
the trial court issued an order enjoining petitioner Urquiaga and/or any of his representatives and
workers from further building a dike, destroying nipa palms or undertaking any activity that
would alter the status of Lot No. 6532-B. But petitioners Urquiaga and Aguirre defied the trial
court as shown by the series of written manifestations with accompanying pictures submitted by
respondents: (a) addition of height to existing dike on 10 September 1985; (b) construction of a
new dike on 28 September 1985; (c) continuation of construction of the same dike on 14 October
1985; (d) further continuation of construction of the same dike on 24 October 1985; (e) cutting
down of nipa palms on 26 May 1986; (f) continuation of the cutting down of nipa palms on 17
June 1986; (g) cutting down of a big piapi tree on 19 September 1986; and, (h) further cutting
down of nipa palms on 27 November 1986. On 13 January 1992 the trial court rendered
judgment: (a) declaring respondent spouses Vicente Cases and Anita Crisostomo as the absolute
and lawful owners and possessors of Lot No. 6532-B.On 31 July 1996 respondent Court of
Appeals modified the decision by deleting the award of actual damages for lack of proof and
explanation on the basis thereof; instead, it ordered petitioners to pay jointly and severally to
respondents P20,000.00 as nominal damages and another P20,000.00 for moral damages. The
rest of the judgment was affirmed. Petitioners then filed a case with the SC maintaining that
respondents acquired title over Lot No. 6532-B through fraud and misrepresentation. They
contend that their predecessors-in-interest had been in possession thereof long before World War
II, which possession has now ripened into ownership, and that respondents are not entitled to any
award of damages.

Issue:
Whether respondents had obtained their title through fraud in misrepresentation and are therefore
not entitled to the award of damages

Ruling:
The SC did not agree with defendants that they are also the occupants and possessors of the
subject lot just because it "is adjacent to their titled property." Precisely, the boundaries of
defendants' titled property were determined, delineated and surveyed during the cadastral survey
of Dipolog and thereafter indicated in their certificate of title in order that the extent of their
property will be known and fixed. Since the subject lot was already found to be outside their
titled property, defendants have no basis in claiming it or other adjacent lots for that matter.
Otherwise, the very purpose of the cadastral survey as a process of determining the exact
boundaries of adjoining properties will be defeated. Even assuming that private respondents
acquired title to Lot No. 6532-B through fraud and misrepresentation, it is only the State which
may institute reversion proceedings under Sec. 101 of the Public Land Act 16 considering the
finding that the subject lot was public land at the time of the sales application.
The law provides:
Sec. 101. — All actions for reversion to the Government of lands of the public domain or
improvements thereon shall be instituted by the Solicitor General or the officer acting in his
stead, in the proper courts, in the name of the Republic of the Philippines.
In other words, petitioners have no standing at all to question the validity of respondents' titles.