G.R. No. 97493 February 8, 1993
PATRICIO B. MANALASTAS and BELEN MANALASTAS, petitioners, vs. HON. COURT OF APPEALS, APOLONIA DELA CRUZ and THE HEIRS OF MOISES CAO, respondents.

FACTS

Petitioners Patricio and Belen Manalastas purchased a parcel of land in Candaba, Pampanga, from spouses Albino Magat and Benigna Sangalang via a Deed of Absolute Sale dated December 30, 1949. Due to road and irrigation construction, the land was subdivided into Lots Nos. 747, 3801, 3802, and 4160. Lot No. 4160, with an area of 2,202 square meters, adjoined Lot No. 745, which belonged to Moises Cao. The Manalastases declared the property for taxation, paid taxes, and had tenants and householders occupying Lot No. 4160 since the purchase. In 1985, petitioners discovered that Moises Cao had obtained a free patent and Original Certificate of Title No. 948 on November 17, 1972, covering Lot No. 745, which included the area of Lot No. 4160. Cao’s free patent application, dated June 9, 1958, originally referred only to Lot No. 745 with an area of 1,050 square meters, but the issued title described it as 3,114 square meters, encompassing Lot No. 4160. Petitioners filed an action for reconveyance, but the trial court dismissed it, citing prescription and lack of evidence of fraud. The Court of Appeals affirmed the dismissal, ruling that the action was filed beyond the prescriptive period.

ISSUE

Whether the Court of Appeals erred in dismissing the action for reconveyance based on prescription and in disregarding petitioners’ claim of possession and alleged fraud or mistake in the issuance of the title to Moises Cao.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ resolution. The Court held that the disposition of public agricultural land by free patent prevails over a deed of sale. The land in dispute was part of the Candaba Public Land Subdivision, hence public land. Moises Cao’s free patent application was duly approved by the Secretary of Agriculture and Natural Resources, and the resulting Original Certificate of Title was issued regularly. There was no evidence of fraud in Cao’s application. Petitioners’ action for reconveyance, filed in 1985, was filed beyond the prescriptive period of four years from the discovery of fraud (if any) or beyond ten years from the issuance of the title in 1972. The Court noted that petitioners could have pursued judicial confirmation of imperfect title under Section 48(b) of Commonwealth Act No. 141 but failed to do so. Thus, the registered title issued via free patent prevails over petitioners’ unregistered claim.