G.R. No. 144095. April 12, 2005.
SPOUSES HAYMATON S. GARINGAN AND JAYYARI PAWAKI, Petitioners, vs. HADJI MUNIB SAUPI GARINGAN, HADJA TERO SAUPI GARINGAN, and HADJA JEHADA SAUPI GARINGAN, Respondents.
FACTS
Respondents Hadji Munib Saupi Garingan, et al., filed an action for Partition and Injunction against their sister Haymaton and her husband Jayyari Pawaki. They claimed their grandfather, Saupi Moro, purchased the 11.3365-hectare land and donated it to their mother, Insih Saupi. Upon Insih’s death, her children, including Haymaton and the respondents, inherited the property. They alleged that after Saupi Moro’s death, Haymaton and Pawaki took over administration, declared it for taxation, and refused to share the income. Petitioners Haymaton and Pawaki claimed ownership by purchase from Jikirum M. Adjaluddin in 1969, supporting this with Transfer Certificate of Title (TCT) No. T-2592 issued in Pawaki’s alias name, “Djayari Moro.”
The Shari’a District Court ruled for the respondents, cancelling TCT No. T-2592 and ordering partition. It found an implied trust, holding that petitioners held the land in trust for the co-heirs. It further ruled that the respondents’ possession, tacked with their predecessors’, had ripened into ownership by prescription despite the donation being verbal.
ISSUE
Whether the Shari’a District Court erred in cancelling TCT No. T-2592 and ordering partition based on implied trust and acquisitive prescription.
RULING
Yes. The Supreme Court reversed the Shari’a District Court’s decision and dismissed the complaint. The Court found that the land was originally part of the public domain. The title held by petitioners was derived from a homestead patent granted to Jikirum M. Adjaluddin, which was subsequently sold to Pawaki. A certificate of title issued pursuant to a homestead patent partakes of a judicial nature and becomes indefeasible and incontrovertible one year from its issuance. The only ground for cancellation is the grantee’s failure to comply with statutory conditions, and the action must be instituted by the Solicitor General in the name of the Republic of the Philippines. Consequently, the respondents, as private individuals, had no legal personality to file an action for the cancellation of such a title. The Court emphasized that the government is the proper party to bring a reversion suit if the land was fraudulently titled. Since the respondents failed to avail themselves of the proper remedy in a timely manner, their action could not prosper. The claim of implied trust and acquisitive prescription was rendered unavailing against a title rooted in a homestead grant, which is protected by the principle of indefeasibility.