G.R. No. 172961 September 7, 2015
PEDRO MENDOZA [DECEASED], SUBSTITUTED BY HIS HEIRS FEDERICO MENDOZA AND DELFIN MENDOZA, AND JOSE GONZALES, Petitioners vs. REYNOSA VALTE, Respondent

FACTS

In 1978, respondent Reynosa Valte filed a free patent application for a 7.2253-hectare parcel of land in Lupao, Nueva Ecija, listing Procopio Vallega and petitioner Pedro Mendoza as witnesses. The Bureau of Lands approved the application, issued Free Patent No. 586435 on December 28, 1978, and Original Certificate of Title No. P-10119 was issued on January 31, 1979. In 1982, petitioners Pedro Mendoza and Jose Gonzales filed a protest against Valte’s application, claiming to be the lawful owners and possessors since 1930 and alleging that Valte procured the free patent through fraud and misrepresentation by suppressing the fact that they were in actual possession of the land. The Department of Environment and Natural Resources (DENR) Secretary initially ruled in favor of the petitioners on January 20, 1994, ordering the reversion of Valte’s title and adjudging the petitioners to have a preferential right to file public land applications. Valte appealed to the Office of the President (OP), which initially set aside the DENR decision for further investigation but later, on April 26, 2000, reinstated the 1994 DENR decision. Valte filed a Petition for Review with the Court of Appeals (CA), which was initially dismissed due to procedural defects but was eventually reinstated by the Supreme Court and remanded to the CA for a decision on the merits. The CA, in its Decision dated December 28, 2005, reversed the OP and reinstated the DENR’s March 11, 1999 decision, which had dismissed the petitioners’ protest, finding them to be mere tenants. Petitioners filed the present Petition for Review.

ISSUE

Whether the Court of Appeals erred in reversing the Office of the President’s decision and in finding that the petitioners failed to prove by clear and convincing evidence that respondent Reynosa Valte committed fraud in securing her free patent and title.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The Court held that the petitioners failed to overcome the burden of proving actual fraud in the acquisition of the free patent with clear and convincing evidence. The existence of fraud is a question of fact, and the findings of the CA, which affirmed the DENR’s factual conclusion that the petitioners were mere tenants and not possessors, are generally binding. The Court noted that the petitioners filed their protest only in 1982, long after the one-year period from the issuance of the patent had lapsed, and such an action for annulment based on fraud must be filed within that period. While Section 101 of Commonwealth Act No. 141 allows the state to initiate reversion proceedings even after the one-year period, this prerogative belongs solely to the state, not to private individuals like the petitioners. The Court found no reversible error in the CA’s decision, which was supported by the evidence on record, including Valte’s free patent application, the joint affidavit of witnesses (including petitioner Mendoza), and the findings of the Land Investigator regarding Valte’s predecessor’s possession.