G.R. No. L-37682, March 29, 1974
Republic of the Philippines, Represented by the Director of Lands, petitioner, vs. Hon. Pedro Samson Animas, in his capacity as Judge of CFI South Cotabato, Branch I, General Santos City, Isagani Du Timbol and the Register of Deeds of General Santos City, respondents.

FACTS

The Republic of the Philippines, through the Director of Lands, filed a complaint to annul Free Patent No. V-466102 and the corresponding Original Certificate of Title (O.C.T. No. P-2508) issued in the name of Isagani Du Timbol, and to secure the reversion of the land to the public domain. The action was grounded on the allegation that the land was classified as forest or timber land, and thus inalienable, based on a 1958 reclassification by the Bureau of Forestry. It was further alleged that Du Timbol obtained the patent and title fraudulently, having never occupied or cultivated the land.
The respondent Court of First Instance dismissed the complaint. It invoked the ruling in Ramirez vs. Court of Appeals, holding that a certificate of title is not void ab initio merely due to fraud in its procurement, unless the fraud consisted of misrepresenting that the land was part of the public domain when it was not. The lower court ruled that the title had become indefeasible due to the lapse of the one-year period for review on the ground of fraud under the Land Registration Act.

ISSUE

Whether a certificate of title issued under a free patent for land classified as forest or timber land can attain indefeasibility, thereby barring an action by the State for its annulment and reversion.

RULING

The Supreme Court granted the petition and reversed the dismissal order. The central legal principle is that the defense of indefeasibility of a Torrens title does not apply against the State in an action for reversion when the land covered is part of the public forest or a forest reservation. Forest or timber lands are not alienable under the Constitution and public land laws; they are beyond the jurisdiction of the Director of Lands to dispose of.
The Court held that when a patent and title are issued for land that is not disposable public land—such as forest land—they are void ab initio. The authority of the Director of Lands extends only to alienable agricultural lands. Since the Bureau of Forestry’s certification established the land’s classification as forest land as early as 1958, the patent issued over a decade later was issued without jurisdiction. Consequently, the resulting certificate of title is a nullity.
Furthermore, prescription does not run against the State. The one-year period for review under the Land Registration Act does not bar an action by the State to recover inalienable public land fraudulently included in a patent. The State’s right of reversion, pursuant to Section 101 of the Public Land Act, is imprescriptible. Even assuming arguendo that the title could no longer be attacked under registration law, an action for reconveyance based on the Public Land Act remains available. The case was remanded to the trial court for further proceedings.