G.R. No. L-32694 and L-33119. July 16, 1982.
FIDEL SILVESTRE and SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, petitioners, vs. COURT OF APPEALS and RUFINO DIMSON (deceased), Substituted by MARIA CAILLES VDA. DE DIMSON, et al., respondents.

FACTS

Respondent Rufino Dimson filed an action for reconveyance and cancellation of title over Lot No. 1185 in Hermosa, Bataan. Dimson claimed the land was private property, previously adjudicated in a cadastral case to spouses Mariano Batungbakal and Hilaria Vergara, from whom he acquired rights via a “Compromiso de Venta” in 1927. He asserted continuous possession and tax payment. Petitioner Fidel Silvestre, however, held Homestead Patent No. 72493 and Original Certificate of Title No. 292 for the same lot, issued by the petitioner Secretary of Agriculture and Natural Resources after due investigation found it to be public land. The trial court dismissed Dimson’s complaint and upheld Silvestre’s title. The Court of Appeals reversed, declaring the lot private land and nullifying the patent and title.

ISSUE

Whether the Court of Appeals erred in nullifying the homestead patent and certificate of title issued to Silvestre based on Dimson’s claim of prior private ownership.

RULING

Yes. The Supreme Court reinstated the trial court’s decision, upholding Silvestre’s title. The legal logic centers on the burden of proof and the incontrovertibility of a Torrens title. In an action for reconveyance, the claimant must establish his superior right by clear and convincing evidence. Dimson failed to meet this burden. He could not produce a copy of the alleged cadastral decision adjudicating the lot to the Batungbakal spouses, nor substantiate the details of such adjudication. His claim rested on mere allegation. In contrast, Silvestre conclusively established that the land was formerly public, his open, continuous possession since 1923, his homestead application, and the subsequent issuance of a patent and title after proper administrative proceedings. Furthermore, the action had prescribed. The title was registered on December 8, 1956. Under the Land Registration Act, a decree of registration becomes incontrovertible after one year. Dimson filed his complaint on May 2, 1959, beyond the one-year period for review. Thus, the registered Torrens title in Silvestre’s name could no longer be impugned. The state’s grant through a homestead patent, once registered, carries the guarantee of indefeasibility central to the Torrens system.