G.R. No. 104296 . March 29, 1996.
Republic of the Philippines, represented by the Director of Lands, petitioner, vs. The Court of Appeals, Heirs of Irene Bullungan, represented by her husband Domingo Paggao and The Register of Deeds of Isabela, respondents.

FACTS

Irene Bullungan applied for and was granted a free patent over a parcel of land in Isabela in 1957, leading to the issuance of Original Certificate of Title No. P-8817. In her application, she stated the land was unclaimed and she had possessed it since 1925. Vicente Carabbacan protested, claiming a portion overlapped with land he had occupied and cultivated since 1947, acquired from a prior possessor. The dispute spawned multiple court cases. In 1972, a court dismissed Carabbacan’s reconveyance suit and upheld Bullungan’s ownership, leading to his ejectio in 1981. Subsequently, a land investigation confirmed Carabbacan’s prior possession. Based on this, the Republic, through the Solicitor General, filed a complaint in 1986 for cancellation of the patent and title on the ground of fraud and misrepresentation.
The Regional Trial Court ruled in favor of the Republic, declaring the patent and title null and void for the disputed portion, finding Bullungan committed fraud by falsely claiming exclusive possession. The Court of Appeals reversed this decision, holding that the State’s action for reversion was barred after the lapse of one year from the issuance of the patent, making the title incontrovertible under the principle of indefeasibility of a Torrens title.

ISSUE

Whether an action for reversion based on fraud in obtaining a free patent is barred after the lapse of one year from the issuance of the patent and corresponding certificate of title.

RULING

No, the action is not barred. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision. The legal logic is that the one-year period for the decree to become incontrovertible refers to judicial decrees in ordinary registration proceedings and does not apply to administrative issuances like free patents. The indefeasibility of a Torrens title is not a shield for fraud. A free patent procured through fraud and misrepresentation is void ab initio, and the corresponding certificate of title is likewise void. The State has an imprescriptible right to bring an action for reversion of public land fraudulently awarded, as the land never legally ceased to be part of the public domain. The Court found the trial court’s factual finding of fraud conclusive—Bullungan falsely represented exclusive possession despite Carabbacan’s prior occupation. Public policy cannot condone allowing one to benefit from fraudulently acquired title. Thus, the State’s action for reversion remains available regardless of the time elapsed.