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CRISTITA BUSTON-ARENDAIN v. ANTONIA GIL

FACTS:

The case involves a complaint filed by the respondents, Antonia Gil and her children, against the spouses Domingo Arendain and Irene Taroy-Arendain, and the spouses Bautista Arendain and Cristita Buston-Arendain. The complaint sought the nullification of titles and other reliefs, alleging that the spouses fraudulently obtained titles to parcels of land in Davao City that they co-owned.

The respondents claimed that they had been illegally deprived of the lands' enjoyment and possession since 1976, and accused the spouses of extending their boundaries and usurping their rights of ownership and possession.

The CENRO, in its answer to the complaint, mentioned a pending administrative case concerning the titles involved, suggesting that the case be pursued before the court after the withdrawal of the administrative case.

The spouses Domingo and Irene and spouses Bautista and Cristita sought the dismissal of the complaint based on lack of cause of action and lack of jurisdiction.

Due to the spouses' failure to file their pre-trial brief and appear for pre-trial, they were issued an order of default. This prompted the spouses Bautista and Cristita to file a petition for certiorari challenging the order, which was dismissed by the Court of Appeals. They then filed a petition for review on certiorari before the Supreme Court, which was also dismissed.

The RTC declared the titles of the spouses Bautista and Cristita null and void, ordering them to vacate the lands covered by the respondents' titles. Only the spouses Bautista and Cristita appealed the decision to the Court of Appeals.

The Court of Appeals denied the appeal, ruling that the spouses' titles covered the same lands as the respondents' titles, and that once a patent is registered, the land becomes private property. The court also held that the doctrine requiring exhaustion of administrative remedies does not apply to private lands.

ISSUES:

  1. Whether or not the doctrine of exhaustion of administrative remedies before recourse to courts applies in this case.

  2. Whether or not the subject matter of the case is a private land.

  3. Whether the free patent applications of Miguel and Antonia Gil over the disputed lots were properly granted and the corresponding certificates of title were validly issued in their names.

  4. Whether the Director of Lands has the power to review homestead patents even after the land becomes private property.

  5. Whether the petitioners committed forum shopping.

RULING:

  1. No, the doctrine of exhaustion of administrative remedies before recourse to courts does not apply in this case. Once a patent is registered and the corresponding certificate of title is issued, the land ceases to be part of the public domain and becomes private property. Therefore, the Director of Lands has neither control nor jurisdiction over the land.

  2. Yes, the subject matter of the case is a private land. The doctrine requiring prior exhaustion of administrative remedies before recourse to courts is confined to land cases involving public lands. It is inapplicable to cases in which the subject matter is private lands.

  3. The free patent applications of Miguel and Antonia Gil over the disputed lots were properly granted and the corresponding certificates of title were validly issued in their names. The pieces of land covered by the certificates of titles assume the character of registered properties and become private property. Any party who is allegedly injured by their fraudulent registration may institute an action for reconveyance.

  4. The Director of Lands has the power to review homestead patents only as long as the land remains part of the public domain. Once the patent is registered and a certificate of title is issued, the land ceases to be part of the public domain and becomes private property over which the Director of Lands has no control or jurisdiction.

  5. The issue of forum shopping is not sufficiently established. Since it was not proven that Civil Case No. 7068 and the present petition involve the same subject matter and/or issues, the court refrains from making a finding that the petitioners are guilty of forum shopping.

PRINCIPLES:

  • Once a patent is registered and the corresponding certificate of title is issued, the land ceases to be part of the public domain and becomes private property.

  • The doctrine of exhaustion of administrative remedies before recourse to courts does not apply to private lands.

  • The principle of exhaustion of administrative remedies is not an ironclad rule and may be disregarded under certain circumstances.

  • A Torrens certificate of title is evidence of an indefeasible title to property.

  • Factual findings of trial courts, when confirmed by the Court of Appeals, are binding and conclusive.

  • Errors of law, and not of facts, are reviewable by the Supreme Court in a petition for review on certiorari.

  • Forum shopping is the institution of two or more actions or proceedings grounded on the same cause on the supposition that one or the other court would make a favorable disposition.

  • The doctrine of non-exhaustion of administrative remedies cannot justify the failure to exhaust administrative remedies.