GR 138953; (June, 2002) (Digest)
G.R. No. 138953 ; June 6, 2002
CASTORIO ALVARICO, petitioner, vs. AMELITA L. SOLA, respondent.
FACTS
Petitioner Castorio Alvarico, the natural father of respondent Amelita Sola, filed an action for reconveyance. He claimed ownership over a parcel of land based on a Deed of Donation executed in his favor by Fermina Lopez on January 4, 1984. Fermina was petitioner’s aunt and respondent’s adoptive mother. Petitioner alleged he took possession of the land thereafter. However, prior to this donation, on May 28, 1983, Fermina had already executed a Deed of Self-Adjudication and Transfer of Rights over the same land in favor of respondent Amelita. This 1983 deed was filed with the Bureau of Lands, and Amelita assumed the obligations under Fermina’s Miscellaneous Sales Application (MSA), ultimately paying the full purchase price. The Bureau of Lands approved the transfer, and an Original Certificate of Title (OCT) was issued in Amelita’s name in 1989.
ISSUE
The crucial issue is who between petitioner and respondent has a better right to the land, which hinges on the validity and effect of the conflicting transfers executed by Fermina Lopez.
RULING
The Supreme Court affirmed the Court of Appeals’ decision dismissing the complaint for reconveyance. The legal logic rests on the principle that a certificate of title issued pursuant to a government grant cannot be collaterally attacked. Respondent Amelita’s OCT, derived from the approved MSA and transfer from Fermina, is evidence of an indefeasible title. An action for reconveyance based on an alleged prior deed of donation constitutes an indirect attack on this title, which is prohibited. Only the State, through the Solicitor General, may institute reversion proceedings to cancel a title originating from a public land grant. Furthermore, the earlier 1983 Deed of Transfer in favor of Amelita vested rights upon its approval by the Bureau of Lands. By the time the alleged 1984 donation to petitioner was made, Fermina no longer had any transferable interest in the property. Petitioner’s claim of a resulting trust, unsupported by any written instrument, was also rejected. Therefore, petitioner failed to establish a superior right warranting reconveyance.