G.R. No. L-12464; August 20, 1918
MARIANO DE LOS REYES, plaintiff-appellee, vs. PABLO RAZON, ET AL., defendants-appellants.

FACTS:
Mariano de los Reyes filed an action for ejectment against Pablo Razon and others, claiming ownership of a parcel of land based on a homestead patent and a corresponding certificate of title issued by the Register of Deeds of Tarlac under the provisions of the Land Registration Act. The defendants denied the plaintiff’s ownership and asserted that the land was part of a larger tract covered by a registered possessory information issued in 1895 to Juan Ysais, whose rights had been conveyed to them. They alleged that the plaintiff had obtained the homestead patent surreptitiously and in fraud of the true owners. During trial, the court rejected the defendants’ evidence intended to prove fraud and prior title, ruling that the plaintiff’s certificate of title was conclusive proof of ownership. The defendants appealed.

ISSUE:
Whether a certificate of title issued upon the registration of a homestead patent, under Section 122 of the Land Registration Act ( Act No. 496 ), is as incontestable and conclusive against all persons as a certificate of title issued pursuant to a judicial decree of registration under the same Act.

RULING:
No. The Supreme Court reversed the trial court’s decision and remanded the case for a new trial. The Court held that a certificate of title based on a homestead patent does not possess the same incontestable character as a Torrens title issued after judicial proceedings under the Land Registration Act.

The proceedings for the issuance of a homestead patent under the Public Land Act are purely administrative, not judicial. Unlike a land registration case which is an action in rem with notice to the whole world, a homestead patent is granted after administrative proceedings within the Bureau of Lands. Section 122 of the Land Registration Act applies only to “public land belonging to the Government.” The registration of a homestead patent and the issuance of a certificate of title thereunder do not operate to divest a prior, valid private title. The patent and the certificate are not conclusive against private individuals claiming under a title anterior to the patent. They merely carry a presumption that the land was public at the time of the patent’s issuance, placing the burden of proof on the party challenging the title. The defendants should have been allowed to present evidence to overcome this presumption and prove their allegation of fraud and prior ownership.