GR 135527; (October, 2000) (Digest)
G.R. No. 135527; October 19, 2000
Spouses GEMINIANO and AMPARO DE OCAMPO and Spouses PEDRO and CRISANTA SANTOS, petitioners, vs. FEDERICO ARLOS, MARY ARLOS, TEOFILO OJERIO and BELLA OJERIO, respondents.
FACTS
Respondents Federico Arlos and Teofilo Ojerio filed an application in 1977 for judicial confirmation of title over three parcels of land in Cabcaben, Mariveles, Bataan. Petitioners, Spouses De Ocampo and Spouses Santos, opposed the application, asserting ownership over portions of the land by virtue of Sales Patents and Transfer Certificates of Title (TCTs) acquired from the government. In 1981, respondents also filed a separate civil case seeking the cancellation of petitioners’ sales patents and TCTs. The Regional Trial Court consolidated the cases and eventually ruled in favor of respondents, ordering the cancellation of petitioners’ titles and confirming respondents’ title to the land. The Court of Appeals affirmed this decision.
ISSUE
The core issue is whether respondents, as private individuals, have the legal personality to initiate an action for the cancellation of the sales patents and certificates of title issued to petitioners by the government.
RULING
The Supreme Court REVERSED the decisions of the lower courts. The legal logic is anchored on the fundamental principle that lands of the public domain, unless classified as alienable and disposable, cannot be acquired by prescription or private occupation. The Court found that the subject lands were not shown to have been classified as alienable and disposable public land prior to the issuance of the sales patents. Consequently, the patents and titles issued to petitioners were void from the beginning, as the government had no authority to dispose of the land. However, a suit for reversion of such property to the State is an action that must be instituted by the Office of the Solicitor General (OSG) in the name of the Republic of the Philippines. Private individuals, like the respondents, have no legal standing to assail the validity of the patents and titles on the ground that the land is inalienable. Their proper remedy is an ordinary action for reconveyance, based on a claim of ownership superior to that of the patentees, which they failed to establish. Since the action was not initiated by the OSG, the lower courts had no jurisdiction to order the cancellation of the patents and titles. The Court thus reinstated petitioners’ titles, without prejudice to any reversion action the OSG may choose to file.