G.R. No. L-14852; May 30, 1961
TEODOSIA NATIVIDAD and RUFINO POQUIZ, plaintiffs-appellants, vs. MARCELIANO NADAL, TOMAS NADAL, FILEMON NADAL and ISABELO MENDOZA, defendants-appellees.

FACTS

Teodosia Natividad, assisted by her husband, filed a complaint to quiet title over a 4.5-hectare portion of a larger parcel covered by Original Certificate of Title No. 1633, issued pursuant to a homestead patent granted to her father, Mariano Natividad. The defendants, led by Marceliano Nadal, opposed the claim. The parties submitted a stipulation of facts. The trial court dismissed the complaint, ruling the land was private property already adjudicated to Marceliano Nadal in a prior land registration case (G.L.R.O. Rec. No. 16366) involving applicant Antonia Tamondong. In that case, the court ordered the exclusion of a specific lot (No. 34) from Tamondong’s application, finding Nadal in possession for over twenty years. This judgment was affirmed by the Supreme Court. Despite this, a homestead patent was later issued to Mariano Natividad, which included the disputed lot. The trial court held this patent void as it covered private land and found the principle of res judicata applicable.

ISSUE

Whether the appellants acquired valid title to the disputed land through the homestead patent and subsequent Torrens title, or whether ownership rightfully vested in the appellee Marceliano Nadal through the prior final judgment in the land registration case.

RULING

The Supreme Court affirmed the trial court’s judgment, with modification. The Court held that the prior land registration case constituted res judicata. The final judgment in that case, which excluded Lot No. 34 from registration in Tamondong’s name based on Marceliano Nadal’s proven possession for over twenty years, conclusively settled Nadal’s ownership. That possession had already ripened into ownership by acquisitive prescription. Consequently, the land was no longer public agricultural land but private property when the homestead patent was later issued to Mariano Natividad. The government cannot grant a homestead patent over land already owned by a private individual; therefore, the patent and the derivative Torrens title (OCT No. 1633) were null and void insofar as they covered Lot No. 34. The annotation on the back of OCT No. 1633, stating the lot was excluded per the Supreme Court’s decision, charged the appellants with knowledge of the defect in their title. Their possession was thus in bad faith and could not ripen into ownership by prescription. The Court modified the dispositive portion to specify that the confirmed ownership pertains to the 45,827-square-meter lot identified in the pleadings, not the broader parcel described in the complaint.