G.R. No. 161424 , December 23, 2009
Republic of the Philippines, Petitioner, vs. Ignacio Leonor and Catalino Razon, Respondents.

FACTS

The petitioner, Republic of the Philippines, represented by the DENR, filed five separate complaints for Cancellation of Free Patent and Original Certificate of Title (OCT) and Reversion against respondents Ignacio Leonor and Catalino Razon over five lots in Lemery, Batangas. The complaints alleged that:
1. For Lot Nos. 10108, 8617, and 10109 (Civil Case Nos. 55-91, 56-91, 57-91), the lots were part of non-disposable foreshore land and did not appear in the cadastral map or records.
2. For Lot Nos. 9398 and 9675 (Civil Case Nos. 58-91, 59-91), the lots, although appearing on the cadastral map, were not officially surveyed or approved; they were verified as part of Lot No. 6192 claimed by intervenor Luisa Ilagan; and they were conveyed to respondents through an “Affidavit of Relinquishment of Rights” from Anacleto Serwelas who had no right over the land. Serious discrepancies existed in the technical descriptions.
Respondents claimed the free patents were regularly issued, they possessed the lots for over 30 years, developed a beach resort, and the action had prescribed. Luisa Ilagan intervened, claiming ownership of Lot Nos. 9398 and 9675 as part of her Lot No. 6192, alleging Serwelas, her tenant, sold portions without her consent.
The Regional Trial Court dismissed all complaints for insufficiency of evidence to prove fraud. On appeal, the Court of Appeals partially granted the petition, declaring Lot Nos. 10108 and 10109 as foreshore lands and ordering the cancellation of their free patents and OCTs. However, it sustained the validity of the titles for Lot Nos. 8617, 9398, and 9675, finding insufficient evidence that they were foreshore lands or part of Ilagan’s property. The Republic filed this petition seeking reversion of the remaining three lots (8617, 9398, 9675).

ISSUE

Whether the Court of Appeals committed a serious error of law in sustaining the validity of the free patents and titles over Lot Nos. 8617, 9398, and 9675 despite the petitioner’s claims that they are inalienable foreshore lands and were procured through fraud.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision. The Court held:
1. On the Nature of the Lots: The petitioner failed to adequately establish that Lot No. 8617 is foreshore land. The complaints themselves did not allege Lot Nos. 9398 and 9675 to be foreshore lands; the claim against them was based solely on alleged fraud. In a reversion proceeding, the burden of proof is on the State to show that the property is inalienable. The State’s evidence was insufficient. The testimony of the DENR witness, Atty. Apuhin, was deemed incompetent as he had no personal knowledge of the alleged non-survey of the lots and merely relied on the cadastral map without conducting a relocation survey or presenting the investigating geodetic engineer.
2. On the Alleged Fraud: The petitioner also failed to prove that the free patents for Lot Nos. 8617, 9398, and 9675 were obtained through fraud or misrepresentation. The alleged irregularities (e.g., lots not appearing in the cadastral list, discrepancies in technical descriptions, fictitious predecessors-in-interest) were not substantiated by clear and convincing evidence. The DENR investigation was not thorough, and no written report was submitted to the court. The Court found no reason to disturb the factual findings of the lower courts, which are conclusive when based on substantial evidence.
3. On Procedural Posture: The Court emphasized that this is a reversion proceeding, not a land registration case. At this stage, a presumption exists that the respondents had established the alienable and disposable character of the lands, having already obtained free patents and OCTs. The State’s evidence was found wanting to overcome this presumption and to warrant cancellation and reversion.
Thus, the Supreme Court upheld the validity of the free patents and titles over Lot Nos. 8617, 9398, and 9675.