G.R. No. 94524 September 10, 1998
SPS. FEDERICO L. REYES AND MAXIMA DELA PAZ; SPS. SILVINA L. REYES AND CESARIO SANTIAGO; SPS. VICENTA L. REYES AND EMILIO ESTEBAN; SPS. IRENEO L. REYES AND JOSEFINA DEL FIERRO; SPS. LEOVIGILDO L. REYES AND JOSEFINA OCHOA; AND FELIX L. REYES, petitioners, vs. COURT OF APPEALS, and the REPUBLIC OF THE PHILIPPINES, respondents.

FACTS

Antonia Labalan filed a homestead application in 1936, which was approved in 1937. She died in 1937, and her children, the petitioners, survived her. Her son Federico Reyes continued to reside on and improve the land. On January 2, 1941, Homestead Patent No. 64863 was issued in the name of the heirs of Antonia Labalan, and Original Certificate of Title (OCT) No. 727 was correspondingly issued. In 1968, Mary Agnes Burns filed a Miscellaneous Sales Application over a 50-hectare property in Subic, Zambales, which included the land covered by OCT No. 727. She reported to the Solicitor General that the petitioners’ titled property was within a forest zone and thus inalienable prior to January 31, 1961. Based on reports from land inspectors and Certification No. 65 issued by District Forester Rogelio Delgado, which stated the land was found to be within alienable and disposable land only on January 31, 1961 per LC Map No. 2427, the Republic of the Philippines filed a complaint for “Cancellation of Title and Reversion” against the petitioners in 1981. The trial court dismissed the complaint, ruling that even if the land was not alienable in 1941, the error was rectified when the government released the land as alienable in 1961, and equity favored the petitioners who acted in good faith. The Court of Appeals reversed the trial court, declaring OCT No. 727 null and void and ordering reversion of the land to the State. The petitioners assailed this decision via a petition for review on certiorari.

ISSUE

Whether the homestead patent and the corresponding Original Certificate of Title issued to the petitioners are valid despite the land being classified as part of the forest zone (and thus inalienable) at the time of their issuance.

RULING

The Supreme Court AFFIRMED the decision of the Court of Appeals. The homestead patent and OCT No. 727 were declared null and void, and the land was ordered reverted to the State. The Court held that the land was indisputably part of the forest lands and not alienable and disposable when the homestead patent was granted and the title issued in 1941. This conclusion was based on Certification No. 65 and Land Classification Map No. 2427, which showed the land was certified as alienable only on January 31, 1961. The Court rejected the petitioners’ arguments. It ruled that the indefeasibility of a Torrens title does not lie against the State in an action for reversion when the title covers inalienable public land. The defense of laches or prescription does not run against the State in such cases. Furthermore, the subsequent release of the land as alienable in 1961 did not cure the defect or validate the void grant. The act was void from the beginning and could not be ratified. The Court emphasized that while it sympathized with the petitioners, the law must be applied strictly.