G.R. No. L-26993 December 19, 1980
Prescioso Ereve, et al., petitioners, vs. Lazaro Escaros and the Honorable Court of Appeals, respondents.

FACTS

The petitioners, heirs of Prudencio Ereve, filed an action for recovery of real property against respondent Lazaro Escaros. The Court of Appeals found that Escaros had been in possession of the disputed land under a claim of ownership since 1952, a possession carrying the legal presumption of a just title. In contrast, the petitioners’ evidence consisted merely of a tax declaration in their father’s name, with boundaries that did not match the property described in their complaint.
Escaros presented a deed of sale, a private document dated July 10, 1928, thumbmarked by the petitioners’ father, Prudencio Ereve, which conveyed the property to him. The due execution and authenticity of this deed were established by Escaros and an attendant witness. Furthermore, it was admitted that Escaros had secured a free patent for the land on June 10, 1932, resulting in the issuance of Original Certificate of Title No. 265. Prudencio Ereve never attempted to recover the property during his lifetime.

ISSUE

Whether the Court of Appeals erred in dismissing the petitioners’ action for recovery of property and in upholding the title of respondent Escaros based on his long possession and free patent.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, finding no substantial basis for reversal. The legal logic rests on several conclusive points. First, the factual findings of the Court of Appeals are binding, as six of the eight errors assigned by petitioners were factual in nature, and the Supreme Court is not a trier of facts. Second, Escaros’s possession since 1952, coupled with the deed of sale from the petitioners’ father, established a superior claim. The father’s inaction during his life reasonably indicated his acknowledgment of Escaros’s right.
Most decisively, Escaros had obtained an indefeasible title of ownership through the free patent and corresponding certificate of title issued in 1932. Under Section 122 of Act No. 496 (the Land Registration Act), such a title becomes conclusive and incontrovertible unless annulled in a direct proceeding. The petitioners’ challenge, filed only in 1961—nearly thirty years after the patent’s issuance—was far too late. The Court emphasized the full protection accorded to free patents, a doctrine rooted in the jura regalia principle, which underscores the state’s original ownership of lands and the conclusive nature of titles granted therefrom. The petitioners failed to overcome this indefeasibility.