GR L 68291; (March, 1991) (Digest)
G.R. No. L-68291; March 6, 1991
ARCADIO, MELQUIADES, ABDULA, EUGENIO, APOLONIO, all surnamed YBAÑEZ, petitioners, vs. THE HONORABLE INTERMEDIATE APPELLATE COURT and VALENTIN O. OUANO, respondents.
FACTS
Private respondent Valentin Ouano filed a homestead application for a parcel of land in 1959, which was approved by the Bureau of Lands. He complied with all legal requirements, including publication and final proof of cultivation and residence. Consequently, an Original Certificate of Title was issued to him in 1963. Ouano peacefully possessed and cultivated the land for years. In 1975, petitioners Arcadio Ybañez and his sons forcibly entered the land, dispossessing Ouano. Ouano filed a complaint for recovery of possession.
Petitioners claimed prior possession since 1930, asserting they had introduced valuable improvements. They contended that the Director of Lands had subsequently found Ouano’s homestead patent to have been improperly issued, as an investigation allegedly showed Ouano never resided on the land and that petitioners were the actual occupants. The trial court ruled in favor of Ouano, ordering petitioners to vacate and pay damages. The Intermediate Appellate Court affirmed with modifications.
ISSUE
Whether the homestead patent and the consequent Torrens title issued to Ouano can be collaterally attacked by petitioners in an action for recovery of possession.
RULING
No. The Supreme Court denied the petition and affirmed the appellate court’s decision. A certificate of title issued pursuant to a homestead patent becomes indefeasible one year after its issuance, enjoying the same protection as a title issued in a judicial proceeding. Such a title can only be challenged in a direct proceeding for its annulment; it cannot be collaterally attacked in an ordinary action for recovery of possession. The alleged findings by the Director of Lands regarding the patent’s impropriety do not constitute a valid direct attack on the title. The proper remedy for petitioners was to file a separate action for the title’s annulment, not to resist an action for possession by challenging the title’s validity. The Court found the petitioners’ claim of prior possession dubious, noting they only forcibly entered the land in 1975, immediately after filing a belated protest with the Bureau of Lands. Ouano’s Torrens title thus remained conclusive evidence of his ownership, and his right to possession was firmly established.