GR 149122; (July, 2007) (Digest)
G.R. No. 149122 ; July 27, 2007
HEIRS OF GREGORIO AND MARY VENTURANZA, Petitioners, vs. REPUBLIC OF THE PHILIPPINES, Respondent.
FACTS
The Republic of the Philippines filed a complaint for the cancellation of Transfer Certificate of Title (TCT) No. 2574 in the name of Gregorio Venturanza and the reversion of the land covered to the public domain. The title, covering 23,944,635 square meters in Buhi, Camarines Sur, was derived from a reconstituted title (TCT No. RT-40 (140)) issued to Florencio Mora. Investigation revealed that the original registration (LRC No. 3480) from which Mora’s reconstituted title was traced covered only 451 square meters in Tigaon, Camarines Sur, not the vast area claimed. The Regional Trial Court ordered the cancellation of TCT No. 2574 and reversion of the land.
The petitioners, heirs of the Venturanzas, appealed, arguing that the reconstituted title issued to Mora had become indefeasible after one year, that they were buyers in good faith, and that the action was barred by a prior Court of Appeals decision in a reconstitution case involving Mora. The Court of Appeals affirmed the trial court’s decision, prompting this petition.
ISSUE
Whether the Court of Appeals erred in affirming the cancellation of TCT No. 2574 and the reversion of the land to the public domain.
RULING
The Supreme Court denied the petition and affirmed the assailed decision. The legal logic is anchored on the fundamental principle that a void title cannot produce legal effects. The reconstituted title (TCT No. RT-40 (140)) in Mora’s name was void because it fraudulently and erroneously encompassed 2,394 hectares of land, originating from an original decree covering only 451 square meters in a different location. A void judgment, such as one based on a fraudulent reconstitution, is deemed non-existent and can be attacked at any time; it does not attain finality in the legal sense. Thus, the petitioners’ derivative title (TCT No. 2574) is likewise void.
Furthermore, the land was found to be part of the inalienable public domain, specifically timberland. Under the Constitution, timberlands cannot be alienated. A certificate of title issued over inalienable land of the public domain is void ab initio. This nullity is not cured by the passage of time or any claim of being a purchaser in good faith. The title must be cancelled regardless of the holder. The prior reconstitution case did not bar the reversion action, as it did not involve or resolve the issues of the original title’s fraudulent nature or the land’s inalienable character.