GR 105630; (February, 2000) (Digest)
G.R. No. 105630 February 23, 2000
REPUBLIC OF THE PHILIPPINES, petitioner, vs. ENRIQUE P. DE GUZMAN, Spouses RIO RIVERA and CAROLINA R. DE GUZMAN, THE CITY REGISTER OF DEEDS OF GENERAL SANTOS CITY and HOECHST PHILS., INC., respondents.
FACTS
The Republic filed a complaint for reversion of Lot 5249 to the public domain and cancellation of titles. The lot was originally awarded by the Board of Liquidators to Eusebio Diones in 1950, who transferred his rights to Enrique de Guzman in 1955. In 1967, de Guzman secured a miscellaneous sales patent and was issued an Original Certificate of Title. He later sold the lot to his daughter and son-in-law, the spouses Rivera, who obtained a Transfer Certificate of Title. The Republic alleged that de Guzman obtained his title fraudulently, as the supporting documents for his sales application were falsified and he was never in actual possession of the land, a legal requirement. The trial court ruled in favor of the Republic, declaring the titles null and void and ordering reversion.
The Court of Appeals reversed the trial court’s decision. It found that the Republic failed to prove its allegations of fraud and falsification by clear and convincing evidence. The appellate court held that the patent and title issued to de Guzman enjoyed the presumption of regularity, and the Republic did not overcome this presumption. It further ruled that the subsequent sale to the Rivera spouses, who were found to be innocent purchasers for value, rendered the title indefeasible.
ISSUE
Whether the Court of Appeals erred in dismissing the complaint for reversion and upholding the validity of the titles derived from the miscellaneous sales patent issued to Enrique de Guzman.
RULING
Yes, the Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision. The Court held that a reversion suit is an action where the State seeks to restore public land fraudulently awarded and patented to private individuals. In such proceedings, the indefeasibility of a Torrens title does not apply when the patent and title are void from the beginning due to fraud. The State must prove the nullity of the patent by preponderance of evidence, not by proof beyond reasonable doubt. Here, the Republic successfully established that de Guzman was never in possession of the land, a fundamental requirement for a miscellaneous sales application. His absence of possession was admitted by his son-in-law. This fatal defect rendered the sales patent void ab initio. Consequently, the Original Certificate of Title issued pursuant to the void patent was also null and void. A void title cannot give rise to a valid title in the hands of subsequent purchasers, regardless of their good faith. Since the root title was void, all subsequent transfers, including to the Rivera spouses and Hoechst Phils., Inc., produced no legal effect. The land correctly reverted to the public domain.