View full case

ALEX A. JAUCIAN v. MARLON DE JORAS

FACTS:

The case involves a dispute over the ownership and possession of certain properties in Del Carmen, Minalabac, Camarines Sur. Quintin De Joras and Marlon De Joras claimed continuous possession of the properties since 1976, after purchasing them from Vicente Abajero. Meanwhile, Alex A. Jaucian alleged that he acquired the properties from Eriberta dela Rosa in 1986 and filed a complaint against Quintin and Marlon for recovery of possession and damages. Quintin filed a complaint against Jaucian for reconveyance and quieting of title. During the pendency of the case, Quintin passed away and was substituted by his heirs. The RTC ordered Quintin and Marlon (substituted by his heirs) to vacate the properties and turn over peaceful possession to Jaucian, as well as to pay monthly rent. It also dismissed their counterclaim and instructed the Land Management Bureau to investigate the grant of the free patent to Jaucian. The Court of Appeals reversed the RTC decision and declared Quintin as the true owner of the properties, ordering the cancellation of Jaucian's title. Jaucian filed a petition for review before the Supreme Court, challenging the decision of the Court of Appeals. The main issue is whether Jaucian is entitled to possession of the properties and to recover damages. The Supreme Court affirmed the decision of the Court of Appeals, ruling that Jaucian is not entitled to possession and damages because the free patent he obtained is null and void. However, the properties cannot be awarded to Quintin and his heirs. The nature of the action filed by Quintin is determined by the allegations in his complaint. The RTC considered it as a reversion action, while the Court of Appeals considered it as an action for reconveyance and declaration of nullity of the free patent.

ISSUES:

  1. Whether Quintin's original complaint should be considered as an action for reversion or an action for reconveyance and declaration of nullity of title.

  2. Whether Quintin and his heirs have legal standing to file an action for reconveyance and declaration of nullity of title.

  3. Whether the free patent under Jaucian's name is null and void.

  4. Whether Jaucian satisfied the requirements for a free patent application.

  5. Whether the free patent issued to Alex Jaucian is valid.

  6. Whether the subject lands should be awarded to Quintin De Juras and his heirs.

RULING:

  1. Quintin's original complaint should be considered as an action for reconveyance and declaration of nullity of title. The Court of Appeals correctly determined that the allegations in Quintin's complaint pertaining to the ownership of the land refer to an action for reconveyance and declaration of nullity of the free patent and certificate of title over the subject properties. The Court relied on the case of Heirs of Kionisala v. Heirs of Dacut, which differentiated an action for declaration of nullity of free patent from an action for reversion. Quintin's allegations in his complaint were consistent with the requirements for an action for declaration of nullity of free patents, specifically, the plaintiff's ownership of the contested lot prior to the issuance of the free patent and certificate of title, and the defendant's fraud or mistake in obtaining these documents of title.

  2. Quintin and his heirs have legal standing to file an action for reconveyance and declaration of nullity of title. The Court of Appeals correctly held that Quintin and his heirs are the real parties-in-interest because the allegations in Quintin's complaint pertain to their ownership of the land prior to the issuance of the free patent and certificate of title. In an action for declaration of nullity of free patent and certificate of title, the real party in interest is the plaintiff who alleges a pre-existing right of ownership over the land in question. The State is not the real party in interest in such a case.

  3. The Court held that the free patent under Jaucian's name is null and void.

  4. Jaucian did not satisfy the requirements for a free patent application. He failed to establish continuous possession of the subject lands for at least 30 years prior to April 15, 1990, as required by law. He also did not submit a map and technical description of the land, along with affidavits proving his occupancy.

  5. The free patent issued to Alex Jaucian is null and void for being obtained by means of fraud and misrepresentation.

  6. The subject lands cannot be awarded to Quintin De Juras and his heirs. However, they are allowed to apply for free patent registration under their own name, provided they can satisfy the requirements, including proving their occupancy of the lands for a period of at least 30 years prior to April 15, 1990, and showing that the lands have been classified as alienable and disposable.

PRINCIPLES:

  • An action for reversion admits State ownership of the disputed land, while an action for declaration of nullity of free patent requires allegations of the plaintiff's ownership of the contested lot prior to the issuance of the free patent and the defendant's fraud or mistake in obtaining the documents of title. (Heirs of Kionisala v. Heirs of Dacut)

  • In an action for reconveyance and declaration of nullity of title, the real party in interest is the plaintiff who alleges a pre-existing right of ownership over the land prior to the grant of title to the defendant. (Heirs of Kionisala v. Heirs of Dacut)

  • An applicant for a free patent must be a natural-born citizen of the Philippines and must not own more than 12 hectares of land.

  • The applicant or his or her predecessor-in-interest must have continuously occupied and cultivated the land for a period of at least 30 years before April 15, 1990.

  • The application must be accompanied by a map and technical description of the land, along with affidavits proving the occupancy from two disinterested persons residing in the municipality or barrio where the land is located.

  • A free patent that 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. Private ownership of land is not affected by the issuance of a free patent over the same land. The Director of Lands has no authority to grant another free patent for land that has already passed to private ownership.

  • To be entitled to free patent registration, the applicant must satisfy the requirements, which may include proving occupancy of the land for a certain period of time and showing that the land has been classified as alienable and disposable.

  • A free patent obtained by means of fraud and misrepresentation is null and void.