G.R. No. 198026 , November 28, 2018
NARCISO MELENDRES, SUBSTITUTED BY HIS WIFE, OFELIA MELENDRES AND CHILDREN JOSE MARI MELENDRES, AND NARCISO MELENDRES, JR., PETITIONERS, V. ALICIA CATAMBAY, LORENZA BENAVIDEZ, IN SUBSTITUTION OF HER HUSBAND EDMUNDO BENAVIDEZ, AND THE REGISTER OF DEEDS OF RIZAL (MORONG BRANCH), RESPONDENTS.

FACTS

Petitioner Narciso Melendres claimed ownership by inheritance of a 1,622-square-meter property in Tanay, Rizal, designated as Lot No. 3302. He alleged that he and his predecessor, Ariston Melendres, had been in open, continuous, and adverse possession of the land for over thirty years, cultivating it as agricultural land. He asserted that a cadastral survey error in 1971 mistakenly included this lot within the homestead patent application of Alejandro Catambay, respondent Alicia Catambay’s predecessor. Consequently, Original Certificate of Title (OCT) No. M-2177 was issued to Alejandro, later transferred to Catambay, and then sold to respondents Spouses Benavidez. Narciso initiated administrative proceedings with the DENR and the Office of the President (OP), which ruled in his favor, finding he was in actual possession and ordering reversion proceedings.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s dismissal of the complaint for reconveyance and/or annulment of title, thereby upholding the Torrens title of the respondents.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The Court held that a Torrens certificate of title is indefeasible and cannot be collaterally attacked. An action for reconveyance, which presupposes an existing title wrongfully registered in another’s name, was not the proper remedy. The core of Narciso’s claim was that the land, being agricultural and possessed by him and his predecessors since June 12, 1945, had been converted to private property by operation of law under the Public Land Act. If this were true, the land would have been inalienable from the public domain at the time Alejandro Catambay applied for a homestead patent. Therefore, the patent and the ensuing OCT were void ab initio. The correct remedy was a direct action for reversion, which is an action in rem that must be filed by the Solicitor General in the name of the Republic of the Philippines. A private individual, like the petitioner, cannot institute such an action. Since Narciso filed a personal action for reconveyance instead of the requisite reversion suit through the State, his complaint was correctly dismissed for failure to state a cause of action. The Court emphasized that ownership is not lost by the failure to file a reversion suit; the State can still initiate it, and the petitioner may vindicate his claim of ownership in a separate appropriate proceeding.