G.R. No. 223822 , October 16, 2019
Republic of the Philippines, represented by the Regional Executive Director, Department of Environment and Natural Resources (DENR), Regional Office No. III, Petitioner, v. Tanduay Lumber, Inc., Verbo Realty and Development Corp., Spouses Clemente and Ma. Lourdes Garcia, John Michael H. Artienda, Spouses Teodoro D.G. Chan and Angelita G. Chan, Licerio M. Libunao, Maricris A. Melchor, Maricris C. Armado, Winston T. Capati and the Register of Deeds of Bulacan, Respondents.

FACTS

The Republic of the Philippines, through the DENR Regional Office No. III, filed a Complaint for Cancellation of Title/Reversion. The case originated from Free Patent No. (III-12) 17306 issued on May 20, 1987, covering Lot No. 3070 in Bulacan, and the subsequent Original Certificate of Title (OCT) No. P-22-C issued on May 25, 1987, in the name of Epifania San Pedro. After San Pedro’s death, Pelagio Francisco executed an Affidavit of Self-Adjudication, leading to the cancellation of OCT No. P-22-C and the issuance of Transfer Certificate of Title (TCT) No. T-7836 in his name on October 25, 1990. On December 3, 1990, Francisco sold the property to Tanduay Lumber, Inc., resulting in the issuance of TCT No. T-8582. The property was subsequently subdivided and sold multiple times to various respondents. The petitioner’s complaint alleged that the alienation of the land by Pelagio Francisco in favor of Tanduay Lumber violated Sections 118, 121, and 122 of Commonwealth Act No. 141 (the Public Land Act), which prohibit the alienation or encumbrance of land acquired under a free patent within five years from its grant. The Regional Trial Court (RTC) granted the respondents’ Special and Affirmative Defenses, dismissing the complaint on the grounds of equitable estoppel and laches. The RTC denied the petitioner’s motion for reconsideration.

ISSUE

Whether the petitioner’s complaint for reversion and cancellation of titles is barred by estoppel and laches.

RULING

The Supreme Court denied the Petition for being moot and academic. The Court held that the passage of Republic Act No. 11231 , or the “Agricultural Free Patent Reform Act,” which took effect on March 30, 2019, rendered the issue moot. Section 3 of RA 11231 provides that agricultural free patents shall be considered as title in fee simple and shall not be subject to any restriction on encumbrance or alienation. Section 4 gives the law retroactive effect, lifting any restrictions regarding acquisitions, encumbrances, conveyances, transfers, or dispositions imposed on agricultural free patents issued before the effectivity of the Act. Since the restriction on the alienation of the land subject of the case within five years from the issuance of the patent under Section 118 of CA 141 has been removed, and the title is now considered title in fee simple not subject to any restriction on alienation or encumbrance, the Government no longer has a legal basis to seek reversion or reconveyance. Consequently, the Complaint for Cancellation of Title/Reversion was dismissed for lack of cause of action.