Primary Holding

The Original Certificate of Title held by the Vallartas is valid and superior, while the Free Patent Title held by the Azarcons is declared null and void and ordered cancelled.

Background

The contested land was originally owned by Dr. Jose V. Cajucom, who sold it in two separate transactions. First, to the Vallartas' predecessors in 1932, and later to the Azarcons in 1959. Both parties subsequently obtained titles, leading to conflicting claims of ownership over the same property.

Facts

• 1. Dr. Jose V. Cajucom previously owned the disputed land.
• 2. In 1932, Dr. Cajucom sold a portion of land to Julian Vallarta Sr.
• 3. In 1959, Dr. Cajucom executed a Deed of Absolute Sale for the same land to the Azarcons, stating it was his paraphernal property inherited from his father.
• 4. In 1960, Dr. Cajucom signed a Waiver and Quitclaim for an excess area in favor of Julian Vallarta Sr., acknowledging the earlier sale.
• 5. In 1961, Rosa Azarcon filed a Free Patent Application, claiming occupation and cultivation since 1934.
• 6. Azarcons were granted Free Patent and Original Certificate of Title No. P-2815.
• 7. In 1965, Vallartas applied for land registration, unopposed by the Bureau of Lands.
• 8. Vallartas were granted Original Certificate of Title No. 0-3093 through registration proceedings.
• 9. Azarcons demanded Vallartas vacate the land in 1968, leading to the lawsuit.

Arguments of the Petitioners

• 1. The land was part of the public domain when their Free Patent was issued.
• 2. Their Free Patent Title is valid and should prevail over the Vallartas' title.
• 3. The Vallartas' title is inferior to their Free Patent Title.
• 4. The lower court erred in not considering their counterclaim as a collateral attack on their title.

Arguments of the Respondents

• 1. The land was private property of Dr. Cajucom, not public domain.
• 2. They and their predecessors have been in continuous possession since 1932.
• 3. Their Original Certificate of Title obtained through registration is valid and indefeasible.
• 4. Azarcons misrepresented facts in their Free Patent application, stating the land was public domain and they were in possession since 1934.

Issues

• 1. Which title should prevail: the Azarcons' Free Patent Title or the Vallartas' Original Certificate of Title?
• 2. Was the land public domain at the time of the Azarcons' Free Patent application?
• 3. Is the Azarcons' Free Patent Title valid given the prior sale and nature of the land?
• 4. Is the Vallartas' Original Certificate of Title valid and superior?

Ruling

• 1. The Supreme Court ruled in favor of the Vallartas.
• 2. The Azarcons' Free Patent Title is null and void because the land was private property at the time of issuance, and the government had no title to convey.
• 3. Rosa Azarcon misrepresented facts in her Free Patent application regarding the land's status and her possession.
• 4. The Vallartas' Original Certificate of Title, obtained through a registration proceeding where the Director of Lands withdrew opposition, is valid and indefeasible.
• 5. The Vallartas' counterclaim was compulsory and not a collateral attack, therefore no docket fees were required.

Doctrines

• 1. Indefeasibility of Title: A certificate of title obtained through registration becomes incontrovertible after one year.
• 2. Prior Title Prevails: Generally, an earlier title is superior in cases of double titling, but this rule presupposes the prior title's validity.
• 3. Free Patent for Public Land Only: Free patents are intended for public lands; they are invalid if issued for private land.
• 4. Ipso Facto Cancellation for Misrepresentation: Under Section 91 of CA 141, titles obtained through fraud or misrepresentation can be automatically cancelled.
• 5. Compulsory Counterclaim: Counterclaims arising from the same transaction are compulsory and do not require separate docket fees.

Key Excerpts

• 1. "A free patent which purports to convey land to which the government did not have any title at the time of its issuance does not vest any title in the patentee as against the true owner".
• 2. "At any rate, said title is now indefeasible and incontestable."
• 3. "where more than one certificate is issued over the land the person holding under the prior certificate is entitled to the land as against the person who relies on the second certificate. This presupposes, however, that the prior title is a valid one. Where, as in the case at bar, it is evident that the prior title of the Azarcons suffers from an inherent infirmity, such a rule cannot be invoked in their favor."

Precedents Cited

• 1. Suva vs. Ventura, 40 Off. Gaz., pp. 47-48, 4th Supp., Aug. 2341, Ct. App: Cited to establish that a free patent cannot convey private land as public land.
• 2. Ramoso v. Obligado, 70 Phil. 86: Cited to reinforce the principle that a free patent issued for private land is void.
• 3. Director of Lands v. Reyes, 69 Phil. 497: Cited alongside Suva and Ramoso, further supporting the principle of free patent invalidity for private land.
• 4. Vital vs. Anora, G.R. No. L-4176, February 29, 1952: Cited with the preceding cases on free patent invalidity and misrepresentation.
• 5. Pajomayo, et al. vs. Manipon, 39 SCRA 677 (1971): Cited to explain the rule of prior title prevails, but clarified that this rule does not apply when the prior title is inherently invalid.

Statutory and Constitutional Provisions

• 1. Section 91 of Commonwealth Act No. 141: Cited as the legal basis for the automatic cancellation of the Azarcons' Free Patent Title due to misrepresentation in the application.