GR 145264; (August, 2005) (Digest)
G.R. No. 145264. August 30, 2005.
NAPOLEON PORTES, SR., MARIA PORTES, and HEIRS OF NAPOLEON PORTES, SR., Petitioners, vs. SEGUNDA ARCALA, et al., Respondents.
FACTS
Respondents, the Arcalas, are the heirs of Vicente and Felisa Arcala, who obtained a homestead patent over Lots 2 and 3 in 1912 and possessed the land until their deaths. Despite this, Felomina Gustilo registered the lots under her name in 1917. A 1930 cadastral decree later amended her title, excluding Lots 2 and 3 due to the prior homestead grant. Nevertheless, Felomina and her successors fraudulently reconstituted titles covering Lot 2. Lot 2 was subdivided; Lot 2-B was sold to spouses Enrique and Pacita Palmares, while Lot 2-A was sold to Napoleon Portes, Sr., petitioners’ predecessor. Respondents, who remained in physical possession, filed a complaint for recovery of possession and annulment of titles in 1977 after discovering the fraudulent acts.
ISSUE
Whether petitioners, as successors-in-interest of Napoleon Portes, Sr., are entitled to retain ownership of Lot 2-A as purchasers in good faith and for value, and whether respondents’ action has prescribed.
RULING
No. The Supreme Court affirmed the lower courts’ decisions, ruling in favor of the respondents. The legal logic rests on the principle that a homestead patent, once issued, places the land beyond the reach of the Torrens system for the benefit of the patentee and their heirs. The 1930 cadastral decree, which excluded Lots 2 and 3 from Felomina’s title, was a final judgment that vested absolute ownership in Vicente Arcala and his heirs. Consequently, all subsequent titles derived from the fraudulently reconstituted title, including that of Napoleon Portes, Sr., are void. Petitioners cannot invoke being purchasers in good faith because the defect in their title traces back to a void source. Furthermore, the action has not prescribed. An action to recover ownership based on a void title is imprescriptible. Moreover, respondents’ possession, coupled with the annotation of an adverse claim in 1970, effectively interrupted any period of prescription. The Court ordered the annulment of petitioners’ title, the turnover of possession of Lot 2-A to respondents, and the payment of attorney’s fees.