VALDEZ v HEIRS OF CATABAS

G.R. No. 201655, August 24, 2020

SECOND DIVISION, HERNANDO

Commonwealth Act No. 141

Doctrine:

The case involves a dispute over Lot No. 4967-C, for which Antero filed a Free Patent
Application (FPA) in 1949. The Petitioner claimed rights over the same land through sales
patent applications made with another person claiming to be the owners of the land. The
heirs of Catabas protested, asserting Antero's existing free patent application. The Office of
the President ruled in favor of Antero, recognizing his vested rights. The Court of Appeals
upheld Antero's application, and the petitioners appealed to the Supreme Court.

Is the free patent application made by Antero valid and binding?

YES. Antero filed a free patent application for Lot No. 4967-C in 1949, later amended in
1952. This application falls under Section 44 of C.A. No. 141, which grants free patents to
natural-born citizens who have continuously occupied and cultivated agricultural public lands
since July 4, 1926 or earlier, and have paid real estate taxes on the land while it was
unoccupied by others. By applying for a free patent, Antero acknowledged that the land is
still part of the public domain and not claimed as private property.

In 1952, Antero filed an amended free patent application under C.A. No. 141. Despite the
land not yet being declared alienable and disposable, the court favored Antero's possession
since 1929 over the petitioners' claims. The subsequent declaration of disposability was
considered in Antero's favor, as his application was still pending and valid.