G.R. No. 272308, February 24, 2025.
SILVESTRE CORPUZ, SUBSTITUTED BY EVELYN CORPUZ, PETITIONER, vs. REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE REGIONAL EXECUTIVE DIRECTOR OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, REGION 1, RESPONDENT.

FACTS

The case stemmed from a Complaint for Annulment of Title and Reversion filed by the Republic of the Philippines against Dominador Arquelada and Silvestre Corpuz (substituted by his wife, Evelyn Corpuz). The Republic sought the annulment of Free Patent Nos. (1-3) 20121 and (1-3) 20105 issued to Silvestre Corpuz covering Lot Nos. 2724 and 2723, and the consequent reversion of these lots to the public domain, alleging they encompass the old riverbed of the Irene River. Silvestre Corpuz had applied for and was granted free patents over the lots in 1978, resulting in the issuance of Original Certificates of Title. In 1988, he executed a Deed of Quitclaim over the properties in favor of Dominador Arquelada, leading to the issuance of Transfer Certificates of Title in Arquelada’s name. In 1999, an investigation by the Department of Environment and Natural Resources (DENR) found the lots were located within the riverbed of the Irene River. Consequently, the DENR Regional Executive Director declared the free patents null and void in 2000 and directed the filing of a complaint for cancellation of the titles. The Regional Trial Court (RTC) partially granted the Republic’s complaint, ordering the reversion of only specific portions of the lots (8,675 sqm in Lot 2723 and 1,135 sqm in Lot 2724) based on trial testimony, and dismissed the case as to Evelyn Corpuz. The Republic appealed. The Court of Appeals (CA) reversed the RTC, ordering the reversion of the entire land covered by the free patents to the public domain, declaring the free patents and all derivative titles null and void ab initio, and setting aside the dismissal as to Evelyn Corpuz.

ISSUE

The core issue is whether the Court of Appeals correctly reversed the Regional Trial Court’s decision by ordering the reversion of the entire land covered by Free Patent Nos. (1-3) 20121 and (1-3) 20105 to the public domain, declaring them null and void ab initio.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. The Court held that the free patents and the resulting titles were void ab initio because the subject lands, being part of a riverbed, were inalienable lands of the public domain. The State’s ownership of such lands is paramount and cannot be lost by prescription. The lack of jurisdiction of the granting authority (the DENR) to issue patents over inalienable land renders the patents and any titles emanating from them void from the beginning. The defense of indefeasibility of a certificate of title does not apply when the patent itself is void. Furthermore, Evelyn Corpuz, as the substitute for the original patentee, was correctly considered a necessary party to the reversion case. The Court of Appeals did not err in ordering the reversion of the entire lots, as the evidence established they were part of a riverbed, and the State is not estopped by the mistake of its agents in issuing the patents over inalienable land.