G.R. No. 165815 ; April 27, 2007
Protacio Banguilan, et al., Petitioners, vs. Court of Appeals, Judge Alfredo Vergara, RTC, Branch 22 Cabagan, Isabela, Brigida Manalo-Velasco, et al., Respondents.

FACTS

Petitioners are successors-in-interest of Serapio Banguilan, who filed a homestead application over a 24-hectare public land in 1925. A protest was filed by Gregorio Manalo, respondents’ predecessor, who also applied for a homestead. The Director of Lands, in a 1979 Decision, rejected Manalo’s application and gave due course to Banguilan’s application, a ruling affirmed by the DENR Secretary in 1989. Despite this administrative adjudication in favor of the Banguilans, the DENR Regional Office issued free patent titles over portions of the land to the heirs of Gregorio Manalo in December 1995. Respondents subsequently filed a successful quieting of title case against petitioners.
In 1997, petitioners filed a suit for reconveyance, later amended to a complaint for “Cancellation/Annulment of Title and Damages.” They argued the titles were unlawfully issued as the land had already been adjudicated to their predecessor. The Regional Trial Court dismissed the complaint, ruling petitioners had no personality to sue as the action was essentially for reversion, which only the State can initiate. The Court of Appeals affirmed this dismissal.

ISSUE

Whether the petitioners’ action for cancellation/annulment of title is actually an action for reversion over public land, which they lack the legal standing to institute.

RULING

The Supreme Court DENIED the petition and AFFIRMED the appellate court’s decision. The Court held that the action, though denominated as one for cancellation or annulment, was in substance an action for reversion. The land in question was undisputedly public land, and the titles sought to be annulled were free patents issued by the government. An action for reversion, governed by Section 101 of the Public Land Act, is an in rem proceeding that seeks to revert public land fraudulently awarded and titled back to the mass of the public domain. This action can only be instituted by the Solicitor General or the Office of the President in the name of the Republic of the Philippines. A private individual, like the petitioners, has no legal standing to file such a suit, even if they claim a better right derived from a prior homestead application. The proper remedy, assuming the patents were fraudulently issued, is for the State to initiate reversion proceedings. The Court clarified that the petitioners’ proper recourse was not a collateral attack on the titles through a private suit, but to seek the intervention of the State to file the appropriate reversion case. The prior administrative decisions in their favor did not grant them a vested title, only a preferential right to a patent, which did not confer upon them the status necessary to sue for the land’s return to the State.