G.R. No. L-32749. January 22, 1988.
SABAS H. HOMENA and ILUMINADA JUANEZA, plaintiffs-appellants, vs. DIMAS CASA AND MARIA CASTOR and the REGISTER OF DEEDS FOR THE PROVINCE OF COTABATO, defendants-appellees.

FACTS

Plaintiffs-appellants Sabas H. Homena and Iluminada Juaneza filed a complaint against defendants-appellees, the spouses Dimas Casa and Maria Castor. They alleged unlawful dispossession and sought to annul the Original Certificate of Title issued to the defendants under a Homestead Patent, claiming it was obtained through fraud. The plaintiffs asserted they had purchased a two-hectare portion of the homestead land from the defendants on June 15, 1952. The deed of sale stipulated that reconveyance would occur after the lapse of the five-year prohibitory period against alienation under the Homestead Law. The plaintiffs contended the defendants failed to honor this agreement.
The defendants moved to dismiss the complaint on grounds of prescription, lack of cause of action, and that the plaintiffs were not the proper party to sue. They argued the 1952 sale was void as the land was still public domain at that time. The plaintiffs opposed, asserting they were not attacking the entire patent but only the two-hectare portion obtained by fraud, making the four-year prescriptive period for fraud applicable. The trial court dismissed the complaint, prompting this appeal.

ISSUE

Whether the trial court correctly dismissed the complaint for lack of a valid cause of action.

RULING

Yes, the Supreme Court affirmed the dismissal. The Court held that the plaintiffs’ cause of action was fundamentally anchored on the deed of sale executed in 1952. This agreement was explicitly designed to circumvent the explicit five-year prohibition against alienation mandated by the Public Land Act ( Commonwealth Act No. 141 ). Consequently, the contract was illegal and void ab initio. As parties to an illegal contract, the plaintiffs could not derive any enforceable rights from it. The judiciary cannot lend its authority to enforce or recognize claims arising from an unlawful agreement.
The Court further ruled that the plaintiffs could not invoke an implied trust based on this illegal transaction. Since the foundational contract was void, no cause of action existed to support their claims for reconveyance or annulment of title on grounds of fraud. Given the absence of a valid cause of action, the subsidiary issues concerning prescription, laches, and the plaintiffs’ legal standing to sue became moot and irrelevant. The lower court, therefore, committed no reversible error in dismissing the complaint.