Republic v.

Aquino (1983)

Facts: Basically, Angeles bought land from Lorenzo. The land was subject of a past court hearing na for
registration of land nung kay Lorenzo pa siya, and the court said public land yung land. Now si Angeles nag-
apply muna for homestead, then he dropped it, applied for confirmation of title na. Now RP opposed said na
res judicata na yung prior judgment na public land na. But for recit detail purposes:

On 1968 May 16 respondent VIvencio Angeles filed with the CFI of Rizal an application for registration
of title over a parcel of land covered by Plan Psu-52079, containing 65K sq. m. situated in San Mateo,
Rizal.
Opposition was filed jointly by Victorino Perez and Dionisio, Conrado, Jose, Nicanor, Lourdes, and
Trinidad Sta. Maria, and individually by Felix Lorenzo, representing the heirs of Victor Lorenzo.
o One of the grounds of opposition: The property was declared public land by the CFI in 1935
in a case entitled Lorenzo, et al. v. Ciriaco Lorenzo, et al. (Material fact ito later)
o After the 1935 case, a homestead application was filed for the same property by Gonzalo
Lorenzo with the Bureau of Lands. Given due course on 12 July 1939.
o On 29 Feb 1956, Gonzalo Lorenzo sold the property to Vivencio Angeles, who on 23 March
1956, filed his own homestead application. approved and given Entry No. 7-1206 on 14 March
1958.
He was allowed to enter into the possession of the land so as to comply with the
cultivation requirements of the Public Land Act.
Since Vivencio Angeles filed for the application for judicial confirmation of title (ito yung opposed
application na nasa unang bullet point), he withdrew his homestead application on 24 May 1969.
On 4 May 1971, the CFI: (i) confirmed Angeles title to the land, (ii) ordered registration in his name,
AND (iii) dismissed the oppositions filed.
o CFI said it was clearly established that Angeles predecessors-in-interest had occupied the land
for so long a time in fact for almost half a century.
o Same court said that Angeles and predecessors-in-interest were in possession of the property
for more than the required period of 30 years, as owners, publicly, continuously, and
uninterruptedly and adverse to any other claim.
o Said that although the land was formerly party of the public domain, Angeles and his p-i-i
claimed title to the land and were in actual possession of the land, and under Sec. 2 of RA 931
the applicant filed a direct application to the Court for registration.
o Also, that Angeles cultivated the land himself, and his p-i-i and appropriating to himself benefit of
all the fruits gathered from the land.
o Corresponding land taxes were also paid.
o The subject land which was previously public domain has been released for private ownership
when the requirements were completely satisfied by Angeles and predecessors-in-interest.
Republic of the Philippines appealed.
o Alleged that the CFI did not have jurisdiction over the application for registration and that it erred
in ruling that Angeles has a registrable title over the lot.
o Alleged that RA 931 does not apply to any person claiming title to land that has been declared
public land in an ordinary registration proceedings invoking judicial confirmation of imperfect
title. Hence, it cannot be invoked to allow the reopening of Land Registration Case No. 1196,
entitled Lorenzo, et al. v. Ciriaco Lorenzo, et al. where CFI declared the land in question as
public land. decision had become final and cannot be disturbed being res judicata.
 Angeles argument:
o RP has no personality to file this petition considering that he had been declared in default for not
having filed its opposition to his application for land registration and that it did not even file a
motion to lift the order of default, nor file a MR.

Issue + Ruling:

WON the application for land registration was already barred by res judicata. YES. Petition granted.

There was already a 1935 Land Registration Case where the CFI declared the property public land.
Decisions which had long become final cannot be disturbed anymore on ground of res judicata.
RA 931 is not applicable to persons claiming title to land declared public land in an ordinary registration
proceedings.
Angeles based his application for registration of title on the provisions of Sec. 48(b) of CA 141, which
allowed OCEN possession and occupation of agricultural lands under bona fide claim of acquisition of
ownership.
o Although neither Angeles nor his predecessors-in-interest were under bona fide claim of
ownership.
o The fact that he had filed a homestead application over the property is an admission that their
possession was not in the concept of an owner.
The main differences between the Land Registration Law and the Public Land Law are:
o Under the first, there exists already a title which is to be confirmed by the court;
o Under the second, the presumption always is that the land applied for pertains to the State, and
that the occupants and possessors claim an interest only in the same by virtue of their imperfect
title or continuous, open, and notorious possession;
o Under the Land Registration Law, the court may dismiss the application of the applicant with or
without prejudice to the right to file a new application for the registration of the same land.
o Under the Public Land Law, the court has jurisdiction or power to adjudicate land in favor of any
of the conflicting claimants.
o Under the LRL, the only risk that an applicant runs is to have his application denied.
o Under the PLL, the applicant runs the risk of losing the land applied for.
o While the goal at which the two laws finally arrive is the same, namely, a Torrens title, which
aims at complete extinguishment once and for all of right adverse to the record title, one law
containing certain advantages not found in the other law, and similarly certain disadvantages,
the two laws provide different routes to travel to attain the ultimate goal.

WON the State is now estopped as the government did not oppose the 1969 application. NO.

It is a well-settled rule in our jurisdiction that the Republic, is usually not estopped by mistake or error on
the part of its officials or agents.