In a significant ruling, the Supreme Court affirmed the rights of long-term possessors of land over those claiming ownership through a defective free patent. The Court emphasized that land possessed openly, continuously, and exclusively for over 30 years by an individual or their predecessors is effectively considered private property. Consequently, any free patent issued by the government over such land is deemed null and void, safeguarding the rights of actual occupants against flawed claims based on public land grants. This decision reinforces the principle that long-term, demonstrable possession establishes a strong claim to ownership, superior to titles originating from improperly issued government patents.

Battling for Tanay Farmlands: When Does Possession Trump a Government Title?

The case revolves around a 1,622-square-meter property in Tanay, Rizal, known as Lot No. 3302. Narciso Melendres, later substituted by his family, claimed ownership through inheritance and decades of possession dating back to the 1940s. Alicia Catambay, along with Lorenza Benavidez, asserted their right based on a free patent obtained by Catambay’s predecessor, Alejandro Catambay, which led to the issuance of Original Certificate of Title (OCT) No. M-2177. The dispute reached the Supreme Court, questioning whether long-term possession could invalidate a title derived from a government-issued free patent. Was the land truly public when the patent was issued, or had it already become private property through decades of continuous occupation?

The Supreme Court delved into the validity of Free Patent No. (IV-1) 001692 and OCT No. M-2177, registered in the name of Alejandro Catambay. At the heart of the petitioner’s complaint was the allegation that OCT No. M-2177, from which the Benavidez spouses derived their title, was improperly issued. Petitioners argued they were the rightful owners due to their actual, public, open, adverse, and continuous possession of the property for over 30 years. The Court underscored that while certificates of title generally become indefeasible after one year, this principle doesn’t apply if a prior valid title exists or if the land isn’t registrable. An action for reconveyance is a remedy for those whose property is wrongfully registered, provided the property hasn’t been transferred to an innocent third party for value.

Building on this principle, the Court cited Agne, et al. v. The Director of Lands, et al., stating that if land is proven to be privately owned, it falls outside the Director of Lands’ jurisdiction, rendering any subsequent free patent and title void. The **indefeasibility of a Torrens title** applies only when the land originally formed part of the public domain. Further, the Court referenced Heirs of Santiago v. Heirs of Santiago, emphasizing that a free patent issued over private land is null and void. Private ownership, demonstrated by registered possessory information or clear, continuous possession, isn’t affected by free patents, as the Public Land Law applies only to public domain lands.

The Court, in the aforesaid case, further explained that the rule on the incontrovertibility of a certificate of title does not apply where an action for the cancellation of a patent and a certificate of title issued pursuant thereto is instituted on the ground that they are null and void because the Bureau of Lands had no jurisdiction to issue them, the land in question having been withdrawn from the public domain prior to the subsequent award of the patent and the grant of a certificate of title to another person.

The key issue, therefore, was whether the free patent issued to Alejandro was valid, given petitioners’ claim that the property was already private. Section 44 of the Public Land Act requires that for a free patent to be issued, the applicant must have continuously occupied and cultivated public agricultural land or paid real estate taxes on unoccupied land.

A careful examination of the facts revealed that Free Patent No. (IV-1) 001692 issued to Alejandro didn’t meet these requisites, making it null and void. This conclusion stemmed from an exhaustive review of the records and findings from various courts and administrative bodies. The Court considered several key points. First, respondent Catambay and her predecessor didn’t actually occupy the subject property. Second, they occupied adjacent property, not the subject land. Finally, petitioners, through their predecessors, had possessed the subject property openly and continuously since the 1940s, cultivating it as a rice field. These findings were substantiated by factual determinations in related cases, including a forcible entry case and DARAB proceedings.

The Court reviewed several pieces of evidence to support their conclusion, finding a wealth of factual findings by lower courts, including previous decisions by the Supreme Court, all indicating the petitioners’ actual possession of the subject property for decades. In Benavidez v. CA, the Court upheld the MTC’s finding that Ariston Melendres was the rightful possessor, consistently cultivating the land as a rice field through tenants. The Court also highlighted the DARAB’s decision, which declared Mendez as the agricultural tenant and ordered Benavidez to reinstate him, further proving the petitioners’ possession.

Furthermore, the Court examined the factual findings by the CA Former Third Division, which reversed the RTC’s initial dismissal of the case. The CA found that the subject property was occupied by Narciso Melendres and his predecessors for about 50 years. The CA Former Third Division further stated that Alejandro Catambay was never an actual occupant and the title issued in his favor was fraudulently issued. The Court stated that such factual findings by the CA Former Third Division were never assailed by the respondents and thus became final and executory.

This approach contrasts with the DENR’s initial findings, which were ultimately reversed by the Office of the President (OP). The OP found that Catambay didn’t cultivate the subject property, but rather, the area being worked on and cultivated by Catambay was included in the title of Mercedes Amonoy. The tenants of the area likewise testified that the land owned by Catambay was included in the title of Amonoy, not the other way around. Moreover, the OP found that Narciso Melendres was actually possessing the said subject property and tilling the area, which was not occupied by either Catambay or Amonoy. The OP thereby found the free patent issued to Catambay as void.

Tax declarations further supported petitioners’ claim, with records showing declarations in the Melendreses’ name dating back to the 1940s. While not conclusive proof of ownership, these declarations, coupled with actual possession, strengthen a claim of title. The Court emphasized that the voluntary declaration of property for taxation shows an intention to obtain title and contribute to government revenue. On the other hand, the earliest tax declarations produced by respondent Catambay covering the subject property are traceable to their predecessor-in-interest, Susana Catolos de Medenacelli. The Court noted that such tax declarations refer to the 1,353-square-meter property adjacent to the subject property and NOT the subject property.

To further prove the assertion that the property actually owned and possessed by Catambay is not the subject property, the Court took notice of the testimony of Arturo Catambay, a relative of Catambay. Catambay testified that the land owned by Alejandro Catambay is not the subject property. He likewise stated that the subject property was continuously occupied by tenants of the Melendreses. Given all these pieces of evidence, the Court found that Free Patent No. (IV-1) 001692 and OCT No. M-2177 issued in favor of Alejandro Catambay were null and void.

Given the nullity of Free Patent No. (IV-1) 001692 and OCT No. M-2177, the Court then determined the validity of the contract of sale entered between Respondent Catambay and Respondents Sps. Benavidez. Even though the title of the Benavidez spouses is traced from the defective title of Catambay, the Court acknowledges the rule that a purchaser is not required to look further than the certificate. However, this rule applies only to innocent purchasers in good faith. This means that they have no knowledge of any defect in the title of the vendor. However, the Court found that the Benavidez spouses are not purchasers in good faith.

A person who deliberately ignores a significant fact which would create suspicion in an otherwise reasonable man is not an innocent purchaser for value. A purchaser cannot close his eyes to facts which should put a reasonable man upon his guard, and then claim that he acted in good faith under the belief that there was no defect in the title of the vendor.

It was found by the Court that the Benavidez spouses had actual knowledge that there were other parties claiming interest over the subject property. Edmundo Benavidez was represented by counsel in the petition for reinvestigation filed by petitioner Narciso. In fact, the CENRO issued an Order to the respondents to maintain the status quo until the case is resolved. Catambay herself testified that the Benavidez spouses had knowledge of the complaints of Narciso Melendres even before they purchased the subject property. The RTC likewise found that Catambay and the Benavidez spouses had knowledge of the conflicts over the subject property. Thus, there is no doubt in the Court’s mind that the Benavidez spouses are not innocent purchasers of the subject property.

FAQs

What was the central issue in this case?	The central issue was whether a long-term occupant’s rights to land are superior to those of someone holding a title based on a later, and potentially flawed, government-issued free patent. Specifically, the court examined whether the Melendres family’s decades of possession outweighed the Catambay’s claim to ownership.
What is a free patent?	A free patent is a government grant of public land to a qualified applicant, typically someone who has occupied and cultivated the land for a specified period. It is a means by which individuals can acquire ownership of public land by meeting certain conditions set by law.
What did the Office of the President (OP) conclude?	The OP reversed the DENR’s decisions, finding that Catambay did not actually cultivate the disputed property. The OP determined that the Melendres family was in actual possession and tilling the land, concluding that the free patent issued in favor of Catambay was therefore void.
Why were the tax declarations important in this case?	Tax declarations served as evidence of the Melendres family’s claim of title over the property. While not conclusive proof of ownership, the consistent filing of tax declarations over many decades, combined with actual possession, bolstered their argument for ownership.
What does it mean to be an “innocent purchaser for value”?	An innocent purchaser for value is someone who buys property without knowledge of any defects in the seller’s title. The Supreme Court found that the Benavidez spouses were not innocent purchasers, as they were aware of the dispute over the property before they bought it.
What was the effect of the Court’s ruling?	The Supreme Court declared the Deed of Absolute Sale between Catambay and the Benavidez spouses null and void and ordered the cancellation of any certificates of title derived from the original certificate of title issued under the flawed free patent. The Court effectively restored the Melendres family’s right to the property.
What remedy is available to someone whose property is wrongfully registered?	An action for reconveyance is available to a person whose property has been wrongfully registered under the Torrens system in another’s name. This allows the true owner to have the title transferred back to them, provided the property hasn’t been acquired by an innocent third party for value.
Why didn’t the indefeasibility of the Torrens title protect the respondents?	The principle of indefeasibility doesn’t apply when the land covered by the title was not originally part of the public domain or when the title was acquired in bad faith. Since the Melendres family had effectively converted the land to private property through long possession, and the Benavidez spouses were not innocent purchasers, the Torrens title offered no protection.

This landmark case underscores the importance of continuous, open, and adverse possession in establishing land ownership. It highlights that long-term occupants can assert their rights, even against those holding titles derived from government grants, provided they can demonstrate a history of uninterrupted possession. The decision serves as a reminder that land titles are not absolute and can be challenged when they conflict with the established rights of possessors who have cultivated the land for generations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Narciso Melendres v. Alicia Catambay, G.R. No. 198026, November 28, 2018