G.R. No. L-2466

FACTS:
Robert Lienau (plaintiff-appellant) sought the inscription in the Court of Land Registration of a 213-hectare tract of land in Angadanan, Isabela. His sole evidence of ownership was a deed executed in 1884 by the provincial governor, pursuant to a resolution of the provincial board. The deed itself stated the land measured 13 hectares, 93 ares, and 76 centares and was issued under the royal decree of August 31, 1888. Lienau argued that the deed’s boundary descriptions should prevail over its stated area, effectively claiming 213 hectares. The lower court denied the application for the excess over 13 hectares and ordered the inscription of only that smaller area, provided Lienau amended his plan accordingly. Lienau appealed.

ISSUE:
Whether the provincial governor and provincial board had the legal authority to issue a deed for a tract of land exceeding 30 hectares, thereby vesting title in Lienau for the claimed 213 hectares.

RULING:
No. The Supreme Court affirmed the lower court’s denial of the application for the excess land and modified the judgment to dismiss the petition entirely, without prejudice to Lienau filing a new petition for any land to which he may properly be entitled.

The Court held that under the applicable Spanish royal decree of August 31, 1888, provincial authorities had no jurisdiction to adjudicate applications for public lands exceeding 30 hectares. Such applications fell under the exclusive jurisdiction of the General Direction of Civil Administration in Manila. Consequently, the provincial governor and board acted without any authority in issuing a deed for 213 hectares. A deed issued wholly beyond the grant of power is void. The principle that official acts are presumed lawful does not apply where there is a complete absence of jurisdiction, as opposed to a mere defective exercise of an existing power.

The Court further found that Lienau could not seek relief under Section 54(4) of Act No. 926 (the Public Land Act), which protects applicants who applied for title under Spanish laws prior to 1894 but failed to receive it through no fault of their own. Here, Lienau’s 1882 application was terminated by the issuance of the 1884 deed. Any subsequent application he made in 1895 for the excess land did not fall within the scope of the said provision.

Since Lienau failed to prove ownership of the 213-hectare tract and his deed was void for lack of authority, his petition was properly denied.