Balboa v Farrales

FACTS:
Sometime in the year 1913, the plaintiff Buenaventura Balboa filled with the Bureau of Lands an application for
homestead, No. 10619, under the provisions of Act No. 926, covering a tract of land in Culis, Hermosa, Bataan. On
July 1, 1919, said Act No. 926 was repealed by Act No. 2874.

On August 11, 1924, said Buenaventura Balboa, for and in consideration of the sum of P950, sold said land to the
defendant Cecilio L. Farrales.

On March 6, 1926, the plaintiff commenced the present action for the purpose of having said sale declared null and
void on the ground of lack of consent on his part and fraud on the part of the defendant, and on the further ground
that said sale was contrary to, and in violation of the provisions of section 116 of Act No. 2874.

trial judge rendered a judgment in favor of the plaintiff and against the defendant, ordering the latter to return to the
plaintiff the land

ISSUE:
which of the two Acts — 926 and 2874 — shall be applied in determining whether the sale in question is valid or not?

RULING:
Act 926 applies and the sale is valid.

The moment the plaintiff had received a certificate from the Government and had done all that was necessary under
the law to secure his patent, his right had become vested before the patent was issued. His right had already vested
prior to the issuance of the patent, and his rights to the land cannot be affected by a subsequent law or by a
subsequent grant by the Government to any other person.

It follows, therefore that the sale of the land in question by the plaintiff Buenventura Balboa to the defendant Cecilio L.
Farrales does not infringe said prohibition, and consequently said sale is valid and binding, and should be given full
force and effect.

RUMARATE vs. HERNANDEZ

FACTS:
Petitioner spouses Teodulo and Rosita Rumarate filed an action for reconveyance of real property and/or
quieting of title with damages against respondent heirs of the late spouses Cipriano Hernandez and Julia
Zoleta. Teodulo averred that Lot No. 379 was previously possessed and cultivated by his godfather,
Santiago, who used to live with the Rumarate family in San Pablo City. Santiago and the Rumarate family
transferred residence to avail of the land distribution in Quezon. Santiago occupied Lot No. 379 cultivating
five hectares thereof. Santiago orally bequeathed his rights over Lot No. 379 to Teodulo and entrusted to
him a copy of a Decision of the CFI of Tayabas, recognizing his Santiago rights over Lot No. 379. Their
family thereafter cleared the land, built a house and planted coconut trees, corn, palay and vegetables
thereon. Santiago executed an "Affidavit (quit-claim)" ratifying the transfer of his rights over Lot No. 379 to
Teodulo. From 1929, Teodulo and later, his wife and 11 children possessed the land as owners and
declared the same for taxation, the earliest being in 1961.

In 1970, Teodulo discovered that spouses Cipriano Hernandez and Julia Zoleta, respondents’
predecessors-in-interest, were able to obtain a title over Lot No. 379. He did not immediately file a case
against respondents because he was advised to just remain on the land and pay the corresponding taxes
thereon.

Respondents claimed that on November 11, 1964, Santiago sold the questioned lot to their parents, the
spouses Cipriano Hernandez and Julia Zoleta. Respondents alleged that the CFI rendered a Decision,
declaring Lot No. 379 as a public land and recognizing Santiago as claimant thereof in the Cadastral
Proceeding. However, no title was issued to Santiago because he failed to file an Answer. Spouses
Cipriano Hernandez and Julia Zoleta filed a motion to re-open the Cadastral Proceeding. The CFI
rendered a decision adjudicating Lot No. 379 in favor of the spouses, in whose name an OCT was issued.
Cipriano Hernandez planted coconut trees on the land through the help of a certain Fredo who was
instituted as caretaker. Fredo informed Cipriano Hernandez that he will no longer stay on the land
because there are people instructing him to discontinue tilling the same.

After the death of the spouses, respondents executed a deed of partition over the subject lot. The trial
court rendered a decision in favor of petitioners. CA reversed and set aside the decision of the trial court.
Hence, the instant appeal.

ISSUE:
The issue to be resolved is to whom should Lot No. 379 be awarded? To petitioners who possessed and
cultivated the lot since 1929 up to the present, but do not have a certificate of title over the property, or to
respondents who have a certificate of title but are not in possession of the controverted lot?

RULING:
In an action for quieting of title, the court is tasked to determine the respective rights of the
parties so that the complainant and those claiming under him may be forever free from any
danger of hostile claim. Under Article 476 of the Civil Code, the remedy may be availed of only
when, by reason of any instrument, record, claim, encumbrance or proceeding, which appears
valid but is, in fact, invalid, ineffective, voidable or unenforceable, a cloud is thereby cast on the
complainant's title to real property or any interest therein. Article 477 of the same Code states that
the plaintiff must have legal or equitable title to, or interest in the real property which is the
subject matter of the suit.

For an action to quiet title to prosper, two indispensable requisites must concur, namely:
(1) the plaintiff or complainant has a legal or an equitable title to or interest in the real property
subject of the action; and
(2) the deed, claim, encumbrance or proceeding claimed to be casting cloud on his title must be
shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal
efficacy

A careful examination of the evidence on record shows that Teodulo possessed and occupied Lot No.
379 in the concept of an owner. After his demise, all his 11 children, the youngest being 28 years old,
continued to till the land. From 1929 to 1960, Santiago never challenged Teodulo’s possession of Lot No.
379 nor demanded or received the produce of said land. For 31 years Santiago never exercised any act
of ownership over Lot No. 379. And, in 1960, he confirmed that he is no longer interested in asserting any
right over the land by executing in favor of Teodulo a quitclaim.

The oral donation in 1929 as well as the 1960 quitclaim ceding Lot No. 379 to Teodulo are void for non-
compliance with the formalities of donation, they nevertheless explain Teodulo and his family’s long years
of occupation and cultivation of said lot and the nature of their possession thereof.

It follows therefore that Teodulo’s open, continuous, exclusive, and notorious possession and occupation
of Lot No. 379 for 30 years, or from 1929 to 1959 in the concept of an owner, earned him title over the lot
in accordance with Sec. 48 (b) of the Public Land Act. Considering that Lot No. 379 became the private
property of Teodulo in 1959, Santiago had no more right to sell the same to spouses Cipriano Hernandez
and Julia Zoleta in 1964. Consequently, the latter and herein respondents did not acquire ownership over
Lot No. 379 and the titles issued in their name are void.

In the instant case, Santiago’s short-lived possession and cultivation of Lot No. 379 could not vest him
title. While he tilled the land in 1925, he ceased to possess and cultivate the same since 1928. He
abandoned the property and allowed Teodulo to exercise all acts of ownership. Hence, spouses Cipriano
Hernandez and Julia Zoleta and herein respondents did not acquire any right over the questioned lot and
the title issued in their names are void, because of the legal truism that the spring cannot rise higher than
the source.
The land was awarded to the petitioners.
Republic v. Hon. Umali
G.R. No. 80687, 10 April 1989

Facts:
1) Land in question originally purchased on installment from the government by Florentina Bobadilla, who
transferred her right thereto in favor of Martina Cenizal, et al. Tomasa and Julio assigned their shares to
Martina, Maria and Gregorio, who, in 1971, signed a joint affidavit that they were entitled to the issuance
of a certificate of title over the said land, and that they had already paid in full.

2) Sec. of Agriculture and Natural Resources executed a deed, and thereafter a TCT. Several transfers
thereafter followed.

3) Republic filed a complaint for reversion on the ground that the original sale of the land was tainted with
fraud based on forgery, and therefore, void ab initio; claimed that Gregorio died in 1943, Maria in 1959,
and could not have signed the joint affidavit.

4) Respondent claimed that they all acquired the property in good faith and for value, invoked estoppel,
laches, prescription and res judicata, others invoked no cause of action as no rights were violated,
government not a real party-in-interest because the land is already covered by Torrens system.

Issue:
May deception/fraud in the registration of title make the sale null and void, so as to make all titles derived
therefrom ineffectual ab initio?

Ruling:
No. The status of the defendants as innocent transferees for value was never questioned, and such
accorded them the protection of the Torrens system, thus rendering the titles obtained indefeasible and
conclusive.

In the present case, the private respondents acquired the land not by direct grant but in fact after several
transfers following the original sales thereof. They are presumed to be innocent transferees for value.

The land now being registered under the Torrens system, the government has no more control or
jurisdiction over it; it is no longer part of the public domain.

NB:
A holder in bad faith is not entitled to the protection of the law.

If the patent and the OCT were procured by means of fraud, the land would not revert back to the State
precisely because it has become a private land. The original transfer was not null and void ab initio but
was only voidable. The land remained private as long as the title thereto had not been voided. In such
case, the nullity arises, not from fraud or deceit, but from the fact that the land is not under the jurisdiction
of the Bureau of Lands (now Land Management Bureau).

Sec. 39, Land Registration Act:

Every person receiving a certificate of title in pursuance of a decree of registration, and every subsequent
purchaser of registered land who takes/taking a certificate of title for value in good faith shall hold the
same free of all encumbrance except those noted on said certificate.

Sec. 44, P.D. 1529 – Property Registration Decree:

Every registered owner receiving a certificate of title in pursuance of a decree of registration, and every
subsequent purchaser of registered land taking a certificate of title for value and in good faith, shall hold
the same free from all encumbrances except those noted on said certificate and any of following
encumbrances which may be subsisting, and enumerated in law.