G.R. No. L-44204 July 11, 1985
BEATERIO DEL SANTISIMO ROSARIO DE MOLO, petitioner, vs. COURT OF APPEALS, JOSE ARROYO, MARIANO ARROYO, PEDRO ARROYO, IGNACIO ARROYO and JESUSA LACSON VDA. DE ARROYO, respondents.

FACTS

Ignacio Arroyo owned properties including “Hacienda Alipion,” comprising Lot No. 1269 (titled) and the adjoining, larger Lot No. 756 (untitled). Upon his first wife’s death, Ignacio executed an extrajudicial partition in 1924, adjudicating Hacienda Alipion to himself, but the description referenced only Lot No. 1269. In 1928, he donated Hacienda Alipion to petitioner Beaterio del Santisimo Rosario de Molo, but the deed again specifically described only Lot No. 1269. Petitioner later leased the entire hacienda to respondent Jesusa Lacson Vda. de Arroyo.
During the lease, Jesusa discovered Lot No. 756 was untitled and considered public land. She informed Sor Rosario Arroyo, petitioner’s prioress, who allegedly stated she preferred her nephews (the Arroyo brothers) acquire the land rather than strangers. Consequently, the Arroyo brothers filed free patent applications. They were granted patents and titles for Lot No. 756 in 1952. Petitioner then filed an action for reconveyance and annulment of titles, claiming fraud and asserting ownership through the 1928 donation.

ISSUE

The core issue is whether petitioner has a valid cause of action for reconveyance and annulment of the free patents and titles over Lot No. 756 issued to the Arroyo brothers.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ dismissal. The legal logic rests on petitioner’s failure to establish a superior right to the property. First, the donation from Ignacio Arroyo was ineffective as to Lot No. 756. The deed’s description explicitly covered only Lot No. 1269. Ignacio could not donate what he did not own, as Lot No. 756 remained public land at the time. Therefore, petitioner acquired no registerable title from him.
Second, petitioner could not claim a right via judicial confirmation of an imperfect title under the Public Land Act. The possession of its predecessor-in-interest, Ignacio, began only around 1905, failing to meet the requirement of possession since July 26, 1894, under the law then in force. While a subsequent amendment required only 30 years of possession, it took effect in 1957, after the Director of Lands had already issued the free patents to the Arroyo brothers in 1952. The brothers’ vested rights, perfected upon patent issuance, could not be defeated by the later law. Consequently, petitioner had no cause of action for reconveyance against the registered owners.