G.R. No. 38612 ; February 23, 1934
Ciriaco Lizada, plaintiff-appellant, vs. Omanan (Bagobo) et al., defendants-appellees.

FACTS

Ciriaco Lizada filed an action for reivindicacion (recovery of ownership and possession) over six tracts of land in Davao. He claimed ownership since 1892 and alleged the defendants, through fraud during his illness, took possession and divided the land among themselves. Some defendants held Torrens titles or free patents issued by the Director of Lands. The lands were also subject to pending cadastral proceedings. The provincial fiscal intervened, asserting the lands were public domain and supporting the free patents granted to some defendants. The parties submitted an agreed statement of facts detailing the free patent applications and titles held by the defendants.

ISSUE

Whether Lizada has a superior right of ownership over the lands, thereby nullifying the free patents and titles issued to the defendants.

RULING

Yes. The Supreme Court reversed the trial court’s judgment. Lizada’s possession since 1892, established by preponderance of evidence, entitles him to a certificate of title under Section 45(b) of the Public Land Act ( Act No. 2874 ). He is conclusively presumed to have performed all conditions for a government grant. The free patents issued to the defendants were unauthorized and void as against Lizada. The defendants, as tenants under rental contracts with Lizada, were estopped from disputing his title, and their procurement of patents was fraudulent. However, Lizada’s claim for damages was disallowed for lack of sufficient evidence. The defendants were ordered to vacate and surrender possession to Lizada.

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