G.R. No. 248505 & G.R. No. 248739, December 07, 2022
RODOLFO SERAPION, SR. AND RODOLFO SERAPION, JR., PETITIONERS, VS. NAPOLEON D. AMBAGAN AND PHILIP AMBAGAN, RESPONDENTS. [G.R. No. 248739] NAPOLEON D. AMBAGAN [SUBSTITUTED BY HIS HEIRS] AND PHILIP AMBAGAN, PETITIONERS, VS. RODOLFO SERAPION, SR. AND RODOLFO SERAPION, JR., RESPONDENTS.

FACTS

Rodolfo Serapion, Sr. and his son Rodolfo Serapion, Jr. (Rodolfo, et al.) filed an Amended Complaint for quieting of title and recovery of possession with damages against Napoleon Ambagan and Philip Ambagan (Napoleon, et al.) before the Municipal Trial Court (MTC) over a 2,439-square meter parcel of land (Lot 15326). Rodolfo, et al. claimed ownership under Original Certificate of Title (OCT) No. M-4863, issued via Free Patent No. (IV-1) 009894 to Rodolfo, Sr., who later donated the lot to Rodolfo, Jr. They alleged Napoleon unlawfully occupied the lot as a caretaker of an adjacent property, applied for his own free patent, and despite the Department of Environment and Natural Resources (DENR) cancelling Napoleon’s free patent in 2005, refused to vacate.
Napoleon, et al. countered that Rodolfo, Sr.’s free patent and title were void due to fraud, as Rodolfo, Sr. was not in actual possession and failed to disclose Napoleon’s prior application and occupation. They asserted they were in open, continuous, adverse possession for over 30 years and sought annulment of Rodolfo, Sr.’s title, reconveyance, and damages.
The MTC dismissed Rodolfo, et al.’s complaint, finding Rodolfo, Sr. lacked authority to file on behalf of his son and failed to prove actual occupation, and declared Rodolfo, Sr.’s free patent and derivative titles null and void due to fraud. It ordered the reversion of the lot to the public domain but did not grant Napoleon’s reconveyance. The Regional Trial Court (RTC) affirmed. The Court of Appeals (CA) denied Rodolfo, Sr.’s petition, upholding the findings of fraud and lack of authority, and referred the case to the Office of the Solicitor General (OSG) for reversion proceedings. The CA also ruled Napoleon, et al. lacked standing to seek reconveyance as their own free patent application was an admission the land was still public. Both parties filed petitions for review.

ISSUE

1. In G.R. No. 248739, whether Napoleon, et al. have standing to seek reconveyance of Lot 15326 and whether reconveyance is the proper remedy.
2. In G.R. No. 248505 , whether the CA erred in denying Rodolfo, et al.’s petition and in ordering the referral of the case to the OSG for reversion.

RULING

The Supreme Court denied both petitions and affirmed the CA Decision and Resolution.
1. On Napoleon, et al.’s Standing and Remedy (G.R. No. 248739): The Court ruled Napoleon, et al. have no standing to seek the annulment of Rodolfo, Sr.’s title or reconveyance. An action for annulment of title or reversion of public land fraudulently granted is vested solely in the State, represented by the OSG. Napoleon, et al.’s remedy was an original action for reconveyance based on their claim of ownership by acquisitive prescription. However, they failed to prove that the land was already private or that they had acquired it by prescription prior to its grant to Rodolfo, Sr. Their filing of a free patent application was an admission the land was still part of the public domain. The cancellation of their free patent by the DENR was final, and they did not appeal it. Thus, the CA correctly ruled they lacked standing, and reversion to the State is the proper course.
2. On Rodolfo, et al.’s Petition ( G.R. No. 248505 ): The Court found no merit. It upheld the lower courts’ finding that Rodolfo, Sr.’s free patent and title were void ab initio due to fraud and misrepresentation. Rodolfo, Sr. admitted he was not in possession of the lot at the time of his application and failed to disclose Napoleon’s occupation, a material fact. Consequently, Rodolfo, et al. acquired no valid title and had no right to quiet title or recover possession. The procedural issue regarding Rodolfo, Sr.’s authority to file the complaint was rendered moot by the substantive finding of a void title. Since the title is void, the land must be reverted to the public domain, and the CA correctly referred the case to the OSG to initiate the corresponding reversion action.