G.R. No. L-47644 August 21, 1987
FELIPA S. LARAGAN, INDEPENDENCIO SIBBALUCA, AURORA C. SIBBALUCA, and ZENAIDA S. VALDEZ, petitioners, vs. HONORABLE COURT OF APPEALS, TEODORO LEAÑO, TOMAS LEAÑO, FRANCISCO LEAÑO, and CONSOLACION LEAÑO, respondents.

FACTS

Petitioners applied for registration of title over a parcel of land in Isabela, claiming acquisition by deed of sale from the Sibbaluca spouses and possession for over 34 years. The Leano siblings opposed, asserting ownership over a 16-hectare southern portion covered by their deceased parents’ Homestead Application No. 58202, in their possession for over 30 years. The trial court granted the petitioners’ application for registration. On appeal, the Court of Appeals affirmed but modified the decision by excluding the southern 16-hectare portion covered by the homestead application, declaring it public land due to both parties’ failure to prove registrable title.

ISSUE

Whether the Court of Appeals erred in excluding the 16-hectare portion from registration and declaring it public land.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The core legal logic rests on the application of Section 48(b) of the Public Land Act, which requires open, continuous, exclusive, and notorious possession and occupation of agricultural lands of the public domain under a bona fide claim of ownership for at least thirty years for confirmation of imperfect title. The Court upheld the appellate court’s factual finding that while petitioners and their predecessor-in-interest had possessed the land for over 30 years, they were not bona fide occupants. The land was originally part of a homestead application by oppositors’ father, Eleuterio Leano. After his death, his widow sold it, and it was eventually given to petitioners’ predecessor. However, the Director of Lands had investigated this transfer and found it violated homestead laws, leading to the cancellation of the application. Consequently, the land reverted to the public domain. Neither party could claim a perfected title. Petitioners’ possession, originating from a void transaction, was not in good faith. Oppositors also failed to perfect their claim after the cancellation. Thus, neither group acquired a vested right, and the excluded portion correctly remained part of the public domain. The Court also found no merit in petitioners’ procedural objections regarding the appeal’s perfection, as the rules of procedure are to be applied liberally and suppletorily in land registration cases.