G.R. No. L-50345. May 14, 1985.
HEIRS OF AGUSTIN FIESTA and SIMEON JUAN, petitioners, vs. THE HONORABLE COURT OF APPEALS and POTENCIANO REANO, respondents.

FACTS

This case originated from Cadastral Case No. 67 in Sta. Rosa, Nueva Ecija, initiated in 1934. Petitioners’ predecessors, Agustin Fiesta and Simeon Juan, filed their respective claims for specific lots in 1940. The cadastral court issued an Order of General Default but took no further action due to World War II. Subsequently, through administrative proceedings, Juan obtained Original Certificate of Title (OCT) No. P-241 for his lots in 1948, and Fiesta obtained OCT No. P-695 in 1951 pursuant to a Homestead Patent. Their heirs succeeded them in possession.
In 1966, long after the petitioners had obtained their titles, private respondent Potenciano Reano intervened in the still-pending cadastral case. He moved to lift the order of default and filed an answer claiming approximately thirty lots, including those already titled in the names of Fiesta and Juan, basing his claim on a deed of sale from another party. The Cadastral Court eventually rendered a decision in 1971 adjudicating the disputed lots to Reano and declaring the homestead patents covering them null and void. The Court of Appeals affirmed this decision.

ISSUE

Whether the cadastral court retained jurisdiction to adjudicate lands already titled under homestead patents issued during the pendency of the cadastral proceedings.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the validity of the petitioners’ titles. The Court held that a cadastral court loses jurisdiction to decree registration of land already decreed and registered under a prior title. Citing its consistent rulings in related cases involving the same cadastral proceeding (De la Cruz v. Reano, Francisco Juan v. Reano), the Court reiterated the doctrine that land granted by the government via a homestead patent and issued an original certificate of title is no longer registerable under the Land Registration Act.
The legal logic is clear: once a homestead patent is issued and an original certificate of title is granted, the land ceases to be part of the public domain and becomes private property. The administrative grant of the patent constitutes a conclusive adjudication of ownership by the government. Therefore, subsequent cadastral proceedings cannot validly reopen or nullify such a vested title. In this case, Juan and Fiesta had been registered owners for over ten and fifteen years, respectively, before Reano even intervened. Their open, continuous possession as homesteaders and later as absolute owners had also perfected their title by prescription. Consequently, the cadastral court’s 1971 decision attempting to adjudicate the already-titled lands to Reano was null and void for lack of jurisdiction. The petitioners’ certificates of title were declared valid and effective.