G.R. No. L-19731; July 31, 1964
ESTANISLAO PANIMDIM, petitioner, vs. THE DIRECTOR OF LANDS, ET AL., respondents.

FACTS

On December 27, 1927, the Director of Lands approved the free patent application of Joaquin Panimdim over a parcel of land (Parcel A). Estanislao Panimdim succeeded to his father’s rights, and a free patent was issued in his name on July 8, 1957, followed by the issuance of Original Certificate of Title No. 9040. A third party, Mariano De la Rosa, persistently asserted a claim over portions of the land. In 1959, acting on De la Rosa’s protest, the Director of Lands ordered a new investigation, including an ocular inspection allegedly conducted without notifying Estanislao Panimdim.
Despite Panimdim’s motion to dismiss on the jurisdictional ground that the land, having been patented and titled, was no longer part of the public domain, the Director of Lands rendered a decision on August 24, 1959. This decision declared the issuance of the patent erroneous for covering more area than Panimdim was entitled to and ordered administrative action to amend and re-issue the patent for a reduced area. The Secretary of Agriculture and Natural Resources affirmed this decision, prompting Panimdim to file the present petition for certiorari.

ISSUE

Whether the Director of Lands retained jurisdiction to review, amend, or cancel the free patent and corresponding certificate of title after its registration, based on a claim of erroneous issuance.

RULING

The Supreme Court granted the petition, setting aside the decision of the Director of Lands. The legal logic is anchored on the principle of indefeasibility of a registered title. The Court, citing the precedent in Republic v. Heirs of Ciriaco Carle, ruled that once a free patent is registered and the corresponding certificate of title is issued, the land ceases to be part of the public domain and becomes private property. Consequently, the Director of Lands loses executive control and jurisdiction over it.
The Court emphasized that while the Director of Lands, under Section 91 of Commonwealth Act No. 141 , possesses the power to review and cancel patents, this authority exists only as long as the land remains part of the public domain. The act of registration segregates the land from public dominion. Following registration, a certificate of title issued pursuant to a homestead or free patent becomes as indefeasible as one issued in a judicial proceeding, becoming incontrovertible after one year from its issuance. In this case, more than two years had elapsed since the registration of Panimdim’s title, rendering it beyond the Director’s power to administratively alter. The proper remedy for an aggrieved party, such as De la Rosa, is not an administrative action before the Director of Lands but a judicial action for reconveyance in court.