De los Angeles vs Santos GR No.

L-19615 Dec 24 1964

FACTS:

In 1959, delos Angeles and 7 others filed for an application for registration of 12 parcels of land in San
Mateo, Rizal.

OPPOSITION filed by: (1) The Province of Rizal filed an opposition claiming that Lot 11 form part of the
Ampid river and creek; and (2) private oppositor Hidalgo also opposed the registration by delos Angeles
claiming that they already acquired Lot 11 by homestead patent. The Director of Lands also issued
homestead patent in favor of Hidalgo over Lot 11 during the pendency of the application of delos
Angeles to register it.

Hence RTC dismissed the application of registration by delos Angeles.

ISSUE: whether the court lost its jurisdiction by the subsequent administrative act of the Director of
Lands of issuing a homestead patent to oppositor

RULING: No. Applicants (delos Angeles) should still be given opportunity to prove registrable title to said
lot. If they can prove their lawful right over the same, the court would have to order a decree of title for
delos Angeles et. al and declare Hidalgo’s homestead patent a nullity which vested no title in the
patentee

as against the real owners.