G.R. No. L-15484; January 31, 1963
Republic of the Philippines, plaintiff-appellant, vs. Ricardo Ramos, The Philippine National Bank and The Registrar of Deeds In and For The Province of Isabela, defendants-appellees.

FACTS

The Republic filed an action seeking the nullity of a homestead patent and title issued to Ricardo Ramos, the cancellation of a mortgage he constituted in favor of the Philippine National Bank (PNB) on the land, and reversion of the property to the State. The complaint alleged that Ramos had previously acquired a homestead patent in Nueva Ecija. When he applied for a second homestead in Isabela, he swore under oath that he had never before filed a homestead application or been a patentee. This false statement, discovered after an investigation prompted by a petition from actual occupants, violated Section 19 of Commonwealth Act No. 141 , as amended, which prohibits an individual from acquiring more than one homestead. The Director of Lands recommended cancellation of the second patent.
The defendants Ramos and PNB filed motions to dismiss. The trial court granted the motions, dismissing the complaint. It ruled, inter alia, that it lacked jurisdiction because more than a year had passed since the Torrens title was issued, rendering it indefeasible; that the complaint failed to allege Ramos made the false statement knowingly and willfully; and that the amendatory law ( Commonwealth Act No. 456 ) was unconstitutional for infringing on constitutional homestead rights and for being discriminatory.

ISSUE

Whether the trial court erred in dismissing the complaint based on the grounds stated in the motions to dismiss.

RULING

Yes, the Supreme Court reversed the dismissal order and remanded the case for trial. On a motion to dismiss, the facts in the complaint are deemed admitted. The legal logic proceeds as follows: First, the trial court’s jurisdictional ruling on the indefeasibility of the Torrens title was premature. Even assuming the title had become indefeasible, the State’s prayer for “any other relief deemed just and equitable” could encompass an action for reconveyance, which is not barred by prescription, especially against the State. Second, the requirement of a knowing and willful false statement pertains to criminal perjury, not to the administrative and civil consequences under the Public Land Act. Whether Ramos acted in good faith is a factual matter requiring evidence, not determinable on a motion to dismiss. Third, the constitutional challenge to Commonwealth Act No. 456 is without merit. The Constitution sets a maximum limit of 24 hectares for a homestead but does not prohibit Congress from setting a lower limit or, as here, prohibiting a second grant entirely. The law is a valid exercise of legislative discretion to ensure equitable distribution of public agricultural lands. Finally, the issue of PNB’s good faith as a mortgagee requires an examination of the certificate of title, a matter for trial. Thus, the complaint sufficiently stated a cause of action warranting a full hearing on the merits.