Case Title:

Doctrine:

In actions in which the validity of free patents issued to the respondents is being questioned on the grounds that they cover mineral
lands and falsification by respondents of their qualification to obtain said patents over the lands in question it is error for the trial court
to conclude, without receiving evidence, that the titles issued to respondents are already indefeasible.

a certificate of title is void when it covers property of public domain classified as forest or timber and mineral lands, Any title issued on
non-disposable lots even in the hands of alleged innocent purchaser for value, shall be cancelled.

The acquittal of the private respondents in the criminal cases for falsification is not a bar to the civil cases to cancel their titles. Reason:
The factual issues of whether or not the lands in question timber or mineral lands and whether or not the private respondents are
entitled to the benefits of Republic Act No. 3872
were not in issue in the criminal cases.

Ponente:FERNANDEZ, J.:

Brief of the Case:

Republic of the Philippines (represented by Director of Lands) commenced an action to annul the free patents granted to herein
defendants, and correspondingly the certificate of title issued to them. Grounds: Misrepresentation & Falsification of Documents.
Lepanto Mining co., intervene on the action and alleged that a portion of titled lands in question is within its ordinary timber license,
and other portion is within its mineral claims. Subsequently, criminal case was filed against the respondents on the ground of
falsification, thus civil action has been pended awaiting resolution of such criminal action. Criminal action was dismissed because of lack
of evidence. Lower court, as the civil case proceeded, ruled in favor of respondents, stating that their title having been duly registered
is not indefeasible; also, their acquittal in criminal action now bars the proceeding of civil action.

SC ruled in favor of petitioner and intervenor (Republic and Lepanto), stating that the respondent was not able to provide evidence that
it satisfied the requirement of the law (eg. whether they are members of the National Cultural Minorities; that they have continuously
occupied and cultivated either by themselves or through their predecessors-in-interest the land in question since July 4, 1955, etc.)
especially that their opposing party, Lepanto Mining, was able to prove its possession over the land in question. The title is also not
consider indefeasible for the reason that it will be void if it covers land of timber and mineral in classification. And also, acquittal in
criminal case does not bar the continuance of civil case for annulment of patent because factual issue of whether the land is timber,
mineral, agricultural is not an issue in criminal case.
Nature of the Case: PETITION to review the order of the Court of First Instance of Baguio City.

Facts:

Republic of the Phils. (represented by Director of Lands) commenced an action for annulment of Free Patents
and of the corresponding original Certificate of Title, on the ground of misrepresentation and false date and
informations furnished by herein defendants (Manuel,et.al) with regard to the land situated in Makayan,
Benguet, Mountain Province (area of the land in question= 58,4169 hectares).

Register of Deeds of Baguio city was made as formal party defendant.

Lepanto Consolidated Mining Co, petitioner herein, filed a motions for intervention, alleging that a portion of
the titled lands in question is within the intervenor’s ordinary timber license, and other portion of said lands is
embraced in its mineral claims.

For the plaintiff and the intervenor, the lands covered by the patents and certificates of title are timber lands
and mineral lands and therefore not alienable.

Before the hearing on the merits of the 3 civil cases, Republic (as represented by Director of Lands), filed in
the CFI of Baguio City 3 criminal cases for falsification of public documents against the private defendants. The
proceeding on the 3 civil cases were suspended pending the outcome of the criminal cases.

Because of insufficiency of evidence, trial court sustained the theory of defense to dismiss the criminal cases.
Defendants then filed a motion to dismiss the civil cases on the grounds that (a) extinction of the penal action
carries with it the extinction of the civil action when the extinction proceeds from a declaration that the fact
from which the civil liability might arise did not exist (b) trial court’s decision to acquit the defendant renders
the civil cases moot and academic (c)trial court has no jurisdiction to order cancellation of the patents issued
by the Director of Lands, etc.

CFI of Baguio dismissed the 3 civil cases for the reasons that:

a. issuance of said Free patents were duly registered with the office of the Register of Deeds of Baguio and
Benguet, pursuant to pertinent provisions of Act 496, as amended and consequently, these properties
became the private properties of the defendants pursuant to same act.

b. such titles enjoy the same privileges and safeguards as Torrens titles.

c. OCT belonging to defendants are now indefeasible which the court has no power to disturb.

d. defendants are ignorant natives of Benguet Province and are members of the so called Cultural
Minorities of Mountain Province, who are the same persons accused in the dismissed criminal case, based
on the same grounds.

Issue:
1. Whether or not the original certificate of title of private respondents were “indefeasible” as they were issued
pursuant to the registration of free patents of the Private Respondents.

2. Whether the acquittal of the private respondents in the criminal cases for the falsification of public
documents barred the civil actions for annulment of the free patents and cancellation of the original
certificates of title of the private respondents.

Ruling:

No to both.

1.Timber and mineral lands are not alienable or disposable.

Pertinent provisions of the Public Land Act (Commonwealth Act No. 141), provides:

“timber and mineral lands shall be governed by special laws; nothing in this Act shall be construed to change
or modify the administration and disposition of the lands commonly called “friar lands” and those which,
being privately owned, have reverted to or become the property of the Commonwealth of the Philippines,
which administration and disposition shall be governed by the laws at present in force or which hereafter be
enacted”.

“President, upon the recommendation of the Secretary of Agriculture and Commerce, shall from time to time
classify the lands of the public domain into…”

a. Alieable or disposable

b. Timber

c. Mineral Lands

and may at any time and in a like manner transfer such lands from one class to another, for the purposes of
their administration and disposition.”

By provision of RA 3872, and in addition to Act. No. 141, it provides:

“A member of the national cultural minorities who has continuously occupied and cultivated , either by himself
or through his predecessors-in –interest, a tract/s of land, whether disposable or not since July 4, 1955, shall
be entitled to the right granted…Provided, that at the time he files his free patent applications he is not the
owner of any real property secured or disposable under this provision of the Public Land Law.”

In this case, there is no evidence that the private respondents are members of the National Cultural Minorities;
that they have continuously occupied and cultivated either by themselves or through their predecessors-in-
interest the land in question since July 4, 1955; and that they are not the owner of any land secured or
disposable under the Public Land Act at the time they filed the free patent applications. The intervenor claims
that it was in possession of the lands in question when private respondents applied for free patents thereon.

It is premature for the trial court to rule as to the indefeasibility of the subject certificate of title. It is well
settled that a certificate of title is void when it covers property of public domain classified as forest or timber
and mineral lands. Any title issued on non-disposable lots even in the hands of alleged innocent purchaser for
value shall be cancelled.

2. The acquittal of the private respondents in the criminal cases for falsification is not a bar to the civil
cases to cancel their titles. The only issue in the criminal cases forfalsification was whether there was
evidence beyond reasonable doubt that the private respondents had committed the acts of
falsification alleged in the information. The factual issues of whether or not the lands in question are
timber or mineral lands and whether or not the private respondents are entitled to the benefits of
Republic Act No. 3872 were not in issue in the criminal cases .

There is need to remand these cases to the trial court for the reception of evidence on (1) whether or
not the lands in question are timber and mineral lands; and (2) whether the private respondents
belong to the cultural minorities and are qualified under Republic Act 3872 to be issued free patents
on said lands.