G.R. No. L-48575 October 15, 1985
HEIRS OF DEOGRACIAS RAMOS and JOSEFA LACUNA, represented by CECILIA L. RAMOS, petitioners, vs. COURT OF APPEALS, ANACLETO P. BERNARDO and PILAR SUAREZ, respondents.

FACTS

The dispute concerns Lot No. 66 in Nueva Ecija. In a 1941 cadastral decision, the Court of First Instance declared the lot public land but reserved the right of Josefa Lacuna, wife of applicant Deogracias Ramos, to file a homestead or free patent application. Lacuna subsequently filed a homestead application, which was denied after opposition from respondent Anacleto Bernardo. Bernardo then successfully applied for a sales patent, leading to the issuance of Original Certificate of Title (OCT) No. P-4621 in his and his wife’s name on May 22, 1967.
In 1969, decades after the original cadastral decision, the heirs of Ramos and Lacuna moved for the modification of the 1941 ruling. The cadastral court, noting that no title for Lot No. 66 had yet been issued, granted the motion and ordered the lot registered in the heirs’ names. Consequently, OCT No. 0-3399 was issued to the petitioners on November 18, 1969. Bernardo then filed an action to nullify this later title, arguing the cadastral court lacked jurisdiction to issue its 1969 order since a Torrens title already existed in his favor.

ISSUE

The principal issue is which certificate of title shall prevail: OCT No. P-4621 issued to Bernardo in 1967 or OCT No. 0-3399 issued to the Ramos heirs in 1969.

RULING

The Supreme Court ruled in favor of respondents Bernardo and Suarez, upholding the validity of OCT No. P-4621. The legal logic is anchored on the conclusiveness and indefeasibility of a Torrens title once issued. The Court emphasized that public lands, once alienated by the government and the corresponding certificate of title is issued, become registered lands under the Torrens system. The title issued is as conclusive and indefeasible as any title originating from judicial registration proceedings.
Therefore, at the time the cadastral court issued its 1969 order directing registration in the petitioners’ favor, the land was no longer public domain but was already private land covered by Bernardo’s valid and existing Torrens title (OCT P-4621). The cadastral court consequently lost jurisdiction over the lot. A cadastral court cannot adjudicate or order the registration of land that is already registered under the Torrens system. Any subsequent title issued under such circumstances is null and void. The Court affirmed the lower courts’ decisions nullifying OCT No. 0-3399, thereby dismissing the petition.