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REPUBLIC v. BENJAMIN GUERRERO

FACTS:

End of the "FACTS" section:

The petitioner argues that the respondent obtained their titles through fraud and misrepresentation. The petitioner claims that the titles should have only covered a smaller portion of land based on a verification survey conducted by the DENR. On the other hand, the respondent asserts that their titles are conclusive and indefeasible under the Torrens system, and that the petitioner failed to prove fraud and misrepresentation.

The Court notes that the issue of fraud is a factual matter, and as a general rule, it does not review factual findings of the trial courts, which are final and conclusive when confirmed by the Court of Appeals. The Torrens system, which aims to avoid conflicts of title and provide security to the registered owner, requires the registration of public lands alienated by the government. Once land is covered by a Torrens certificate, the owner can rely on it without further inquiry.

However, Section 38 of Act No. 496 grants the right to a person who has been deprived of land to seek the reopening or revision of a decree of registration obtained through actual fraud. This provision allows for an exception to the indefeasibility of a title acquired through the Torrens system.

End of the "FACTS" section:

ISSUES:

  1. Whether the petitioner has presented sufficient evidence to prove actual and extrinsic fraud in procuring the sales patent and certificate of title.

  2. Whether the petitioner was prevented from asserting its right over the lot in question and from properly presenting its case by reason of the alleged fraud.

  3. Whether the protest filed by Angelina Bustamante with the Bureau of Lands can be considered a petition to review the decree of registration issued to the respondent.

  4. Whether the petition for review filed by the Director of Lands with the Regional Trial Court (RTC) was filed within the prescribed one-year period.

RULING:

  1. The Supreme Court ruled in favor of the respondent and held that the petitioner failed to prove actual and extrinsic fraud in procuring the sales patent and certificate of title. The court also found that the petitioner was not prevented from asserting its right over the lot in question and from properly presenting its case due to fraud. Therefore, the petition was denied.

  2. The protest filed by Angelina Bustamante with the Bureau of Lands cannot be considered in the context of a petition to review the decree of registration issued to the respondent. The law expressly states that a petition for review of a decree of registration shall be filed in the "proper Court of First Instance" (now Regional Trial Court). The review of a decree of registration requires a full-blown trial before a regular court, where each party can present their case and where each of them must establish their case by preponderance of evidence. The concept of "preponderance of evidence" refers to evidence which is of greater weight, or more convincing, than that which is offered in opposition to it. On the other hand, substantial evidence refers to such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Therefore, the protest filed with the Bureau of Lands did not comply with the proper procedure for petitioning the review of a decree of registration.

  3. The petition for review filed by the Director of Lands with the RTC was not filed within the prescribed one-year period. It was filed on November 7, 1989, which was way beyond the one-year period prescribed by law.

PRINCIPLES:

  • Section 38 of Act No. 496 recognizes the right of a person deprived of land to institute an action to reopen or revise a decree of registration obtained by actual fraud.

  • Fraud may be actual or constructive, and extrinsic or intrinsic.

  • Relief on the ground of fraud will not be granted where the alleged fraud goes into the merits of the case, is intrinsic and not collateral, and has been controverted and decided.

  • The party alleging fraud or mistake in a transaction bears the burden of proof.

  • Fraud must be established by clear and convincing evidence, not just preponderance of evidence.

  • The presumption of regularity in the performance of official functions must be respected.

  • The issuance of sales patent and certificate of title should be made in accordance with the procedure laid down by the Public Land Act.

  • Public officers are deemed to have regularly performed their official duties, and their actions are presumed to be regular and proper.

  • Proceedings for land registration that lead to the issuance of a certificate of title are presumptively regular and proper.

  • The one-year period to contest a certificate of title commences from the issuance of the patent.

  • Prescription does not run against the State in cases of fraudulent or unlawful inclusion of land in patents or certificates of title.

  • Once a piece of land is covered by a registered patent and certificate of title, it ceases to be part of the public domain and becomes private property.

  • The Torrens system was adopted to guarantee the integrity of land titles and protect their indefeasibility. Once the claim of ownership is established and recognized, the title should be considered valid and secure.

  • The Torrens system is based on the principle of buyer's good faith. If a person purchases a piece of land on the assurance that the seller's title is valid, their acquisition should not be rendered ineffectual later on.

  • The Torrens system aims to quiet title to land and put a stop to any question as to the legality of the title, except claims that were noted in the certificate at the time of registration or that may arise subsequent thereto.

  • The government, recognizing the worthy purposes of the Torrens system, should be the first to accept the validity of titles issued thereunder once the conditions laid down by the law are satisfied.

  • The integrity of the Torrens system should not be compromised by the ineptitude and inefficiency of land registration officials, in the absence of proof of the titleholder's complicity in fraud or manifest damage to third persons.