G.R. No. 218418, November 8, 2017
Republic of the Philippines, represented by the Regional Executive Director, DENR, Region IV, Manila, Petitioner, vs. The Heirs of Meynardo Cabrera, et al., and the Register of Deeds of Oriental Mindoro, Respondents.

FACTS

In 1971, Meynardo Cabrera obtained Free Patent No. 516197 and Original Certificate of Title No. RP-132 (P-9193) for two lots in Roxas, Oriental Mindoro, based on possession since 1936. A portion (Lot 1-A) was later transferred to Consolacion Dimaculangan Cabrera and subsequently sold to various purchasers. In 1994, prompted by a petition from third-party claimants, a DENR investigation report recommended the cancellation of the free patent, concluding the land was part of the public domain classified as forest land. The Republic subsequently filed a complaint for annulment of the patent and titles and reversion of the property to the State, relying on the DENR report and certifications from the National Mapping and Resource Information Authority (NAMRIA). These NAMRIA certifications stated the land was reclassified as forest land in 1949, based on an annotation on a 1924 land classification map.
The Regional Trial Court dismissed the complaint, a decision affirmed by the Court of Appeals. The CA ruled that the Republic failed to overcome the presumption of regularity in the issuance of the free patent and the consequent indefeasibility of the title. It found the evidence of reclassification—primarily the NAMRIA certifications referencing an annotated map—insufficient to prove the land was inalienable forest land at the time of the patent application. The Republic elevated the case via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaint for reversion, thereby upholding the validity of Free Patent No. 516197 and the derived titles.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The Court reiterated that in an action for reversion, the burden of proof rests heavily on the State to establish that the land is part of the public domain. The State must conclusively prove that the land was not alienable and disposable at the time the free patent was granted. In this case, the Republic’s evidence was deemed insufficient. The NAMRIA certifications, which were based on an annotation on a 1924 map, were not accompanied by a certified true copy of the map itself or its technical descriptions. This failure violated the best evidence rule, as the certifications were merely secondary evidence of the map’s contents. Without the map, the Court could not verify the alleged reclassification.
Furthermore, the DENR investigation report itself was problematic. While it recommended cancellation, it also acknowledged the patentee’s long-term possession and explicitly stated that the rival claimants had no better right. The Court emphasized that a free patent, once registered and a certificate of title issued, becomes indefeasible after one year. To overturn this, the State’s evidence must be clear, positive, and convincing. Here, the evidence was ambiguous and incomplete. Therefore, the State did not discharge its burden, and the titles issued to the respondents must be upheld. The ruling protects the stability of land titles acquired under the Torrens system.