GR L 66696; (July, 1986) (Digest)
G.R. No. L-66696 July 14, 1986
FRANCISCA ARSENAL and REMEDIO ARSENAL, petitioners, vs. THE INTERMEDIATE APPELLATE COURT, HEIRS OF TORCUATO SURALTA, and SPOUSES FILOMENO PALAOS and MAHINA LAGWAS, respondents.
FACTS
Filomeno Palaos, a member of the cultural minorities, obtained a homestead patent over a parcel of land in 1954. Within the five-year prohibitory period from the issuance of the patent, Palaos sold a four-hectare portion to Torcuato Suralta in 1957. Suralta immediately took possession, cultivated the land, and introduced permanent improvements. In 1967, Palaos executed another deed of sale, this time covering the entire lot, including the four hectares already sold to Suralta, to spouses Francisca and Remedio Arsenal. The Arsenals registered this later sale and obtained a transfer certificate of title for the whole lot. Suralta, upon discovery, filed an action for annulment of the Arsenals’ title over the four-hectare portion he purchased.
ISSUE
The core issue is which of the two sales transactions—the 1957 sale to Suralta or the 1967 sale to the Arsenals—conveys a valid title over the disputed four-hectare portion of the homestead land.
RULING
The Supreme Court declared both sales null and void. The 1957 sale to Suralta was executed within the five-year prohibitory period from the grant of the homestead patent, violating Section 118 of Commonwealth Act No. 141, the Public Land Act. This provision is a mandatory statutory prohibition designed to preserve the grant for the homesteader and his family, making any alienation within that period absolutely void. The subsequent 1967 sale to the Arsenals, which encompassed the same property, is likewise void because it involved land already encumbered by a previous, albeit void, transaction. The Court emphasized that the doctrine of estoppel cannot validate a contract expressly prohibited by law or against public policy. Consequently, the Arsenals’ derived title is invalid. The Court ordered the cancellation of the transfer certificate of title issued to the Arsenals and the reissuance of an original certificate for the disputed portion in the names of the original homesteaders, Palaos and Lagwas, subject to possible government reversion proceedings. Suralta was ordered to be reimbursed the purchase price, with the value of his improvements deemed compensated by the fruits received from his long possession.