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10.

a) According to the case of Magay vs Estandian (G.R. No. L-28975), the principal
question to be resolved is whether appellant can question the validity of Original
Certificate E-2020 issued to Soledad and of the subsequent issuance of Transfer
Certificate of Title No. 2W4 to the plaintiff as a consequence of the registration of
the deed of sale executed by Soledad on the ground that the Original Certificate of
Title was allegedly fraudulently issued to Soledad. In this case, appellants appealed
directly to the Supreme Court that only questions of law are involved.
b) According to the case of Samonte vs Sambilon (G.R. No. L-12964), a collateral
attack is prohibited since a homestead patent for which a certificate of title issued
has the same effect and validity as a Torrens Title.
c) According to the case of Director of Lands vs Gan Tan (G.R. No. L-2664), it was
reiterated that a Torrens title cannot be collaterally attacked even if the petitioner
complied with all the requirements of the law.
d) According to the case of Ybanez vs IAC, the certificate of title issued to private
respondent attained the status of indefeasibility because the 1year period has
lapsed. As a result, it can no longer be reviewed on the ground of actual fraud. Even
considering that petitioner filed a protest before the Bureau of Lands, reopening is
already not allowed. The settled rule is that a decree of registration and the
certificate of title issued may be attacked on the ground of actual fraud within one
year from the date of its entry directly, not collaterally.

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