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 reversion to the public domain of Lot Nos. 2723 and 2724 in Caoayan, Ilocos Sur, which were covered by Free Patent Nos. (1-3) 20105 and (1-3) 20121 issued to Silvestre Corpuz in 1978, and subsequent Original Certificates of Title. The Republic alleged these lots encompassed the old riverbed of the Irene River. In 1988, Silvestre executed a Deed of Quitclaim over the properties in favor of Dominador Arquelada. An investigation by the DENR in 1999-2000 found the lots were situated within the Irene River area, leading to orders declaring the free patents null and void. The Regional Trial Court (RTC) partially granted the 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 a geologist’s 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 patents and all derivative titles null and void ab initio, and setting aside the dismissal as to Evelyn Corpuz.

ISSUE

The core issue, as presented in the petition, is whether the Court of Appeals erred in reversing the RTC decision and ordering the reversion of the entire land, based on the lack of positive government act reclassifying the land as alienable and disposable, and the alleged fraud in securing the patents.

RULING

The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals. The Court held that the State may bring an action for reversion of public land fraudulently awarded to private individuals, and such action is imprescriptible. The burden of proof rests on the grantee to show the land is alienable and disposable. In this case, the petitioner failed to present any certification or positive act from the relevant government agency proving that the subject lands, which were part of a riverbed, had been classified as alienable and disposable prior to the grant of the free patents. The absence of such proof rendered the patents void ab initio. Consequently, titles emanating from void patents are also void. The Court further ruled that Evelyn Corpuz, as the substitute for the original patentee, is a necessary party to the action for annulment of the patents and titles. The CA correctly ordered the reversion of the entire land covered by the void patents to the public domain.