G.R. No. 131667 July 28, 2005
HEIRS OF CARLOS ALCARAZ, Petitioners, vs. REPUBLIC OF THE PHILIPPINES, BENJAMIN DAYOR and ADELA ALCARAZ, Respondents.

FACTS

Julian Alcaraz possessed a parcel of land in Meycauayan, Bulacan. Upon his death, his three children—Carlos, Timotea, and Igmedio—succeeded him, with each occupying a one-third portion. Their respective heirs maintained this physical partition. In 1974, Maria Paz Alcaraz-Gomez, representing the heirs of Carlos Alcaraz, filed a free patent application covering the entire lot. After investigation, Free Patent No. (III-6) 000705 and Original Certificate of Title No. P-1887 were issued in the name of the heirs of Carlos Alcaraz. The heirs of Timotea and Igmedio later filed a formal protest, alleging fraud and misrepresentation, as the patent was obtained for the whole property despite their established co-ownership.
The Republic, through the Solicitor General, filed a complaint for annulment and reversion. The other heirs successfully intervened. The Regional Trial Court declared the patent and title null and void ab initio, recognized the intervenors’ co-ownership, and ordered the property’s subdivision. On appeal, the Court of Appeals affirmed the nullity of the patent and title but set aside the trial court’s orders for subdivision and partition, holding that such affirmative relief for the intervenors could not be granted in a reversion case filed by the State.

ISSUE

Whether the Court of Appeals erred in affirming the nullity of the patent and title but setting aside the trial court’s orders for partition and recognition of co-ownership.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is clear: a reversion suit, filed by the State under its parens patriae authority, aims to cancel a fraudulently acquired patent and title and revert the land to the public domain. It is not a proper vehicle for adjudicating private ownership disputes or granting affirmative relief like partition to private claimants. The trial court, in a reversion case, exceeds its jurisdiction when it awards the land to private intervenors or orders its subdivision. Such actions effectively dispose of public domain land without the State’s consent and bypass the requisite public land grant procedures.
The Court of Appeals correctly limited its ruling to the nullification of the patent and title obtained through misrepresentation, as the heirs of Carlos Alcaraz applied for the entire lot despite only being entitled to a one-third share. The appellate court properly disregarded the trial court’s erroneous grant of partition, as this relief is obtainable only in a separate ordinary action among the co-owners. The State’s success in its reversion action does not automatically confer title upon the intervenors; the land reverts to the mass of public domain, and the intervenors must pursue their claims through the appropriate legal avenues.