G.R. No. 212611 February 11, 2019
HEIRS OF BATORI, represented by GLADYS B. ABAD, Petitioner vs. THE REGISTER OF DEEDS OF BENGUET and PACITA GALVEZ, Respondents

FACTS

The heirs of Batori, represented by Gladys Abad, sought the annulment of Original Certificate of Title (OCT) No. P-21449 issued to respondent Pacita Galvez. Batori had possessed a parcel of land in La Trinidad, Benguet since 1945, applied for a free patent in 1956, and his heirs continued possession after his death. In 2000, Abad discovered an amended survey plan subdividing Batori’s lot, with one portion (Lot 1-A) named in favor of Galvez, who was not an heir. Abad also learned of a potential overlap with a survey plan (PSU No. 1000175) under Johnson Andres. After a DENR protest, the Secretary upheld both survey plans and directed segregation. Despite an appeal to the Office of the President, Galvez secured a free patent and OCT in 2007 based on PSU No. 1000175, prompting the heirs to file a complaint for annulment alleging fraud.
The Regional Trial Court (RTC) initially granted the complaint, finding Galvez guilty of fraud as her application covered part of Batori’s land. However, upon Galvez’s motion for reconsideration, the RTC reversed itself, ruling that Galvez relied on a final DENR decision validating her survey plan and thus acted without fraud. The Court of Appeals (CA) dismissed the heirs’ appeal for procedural lapses and affirmed the RTC’s reversal on substantive grounds, noting the finality of the DENR decision.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s dismissal of the complaint for annulment of title, thereby upholding the validity of Galvez’s OCT.

RULING

The Supreme Court denied the petition and affirmed the CA resolutions. The Court held that the RTC’s reversal of its own decision upon a motion for reconsideration was a valid exercise of judicial power to correct errors, not an indication of irregularity. On the substantive issue, the Court emphasized that a certificate of title issued pursuant to a free patent becomes indefeasible one year after its issuance, and a direct attack for annulment based on fraud must be proven by clear and convincing evidence. Here, the DENR Secretary, whose decision was affirmed by the Office of the President, had already upheld the validity of Galvez’s survey plan (PSU No. 1000175) and found no fraud in her application. Galvez’s reliance on this final administrative decision negated any finding of deliberate fraud. The principle of res judicata thus barred relitigation of the land’s status. The heirs’ previous procedural victories on ancillary motions did not equate to a favorable ruling on the merits. Consequently, the CA correctly found no reversible error in the RTC’s dismissal of the complaint.