SAMUEL ESTRIBILLO, CALIXTO P. ABAYATO, JR., RONGIE D. AGUILAR, TACIANA D.

AGUILAR,
ARTEMIO G. DE JUAN, ESTANISLAO DELA CRUZ, SR., EDGAR DUENAS, MARIO ERIBAL,
REYNALDO C. ESENCIA, EMMA GONZAGA, RUBEN A. IBOJO, SAMUEL JAMANDRE, HILARION
V. LANTIZA, ANSELMO LOPEZ, TERESITA NACION, CHARIE E. NASTOR, NELSON L. NULLAS,
CARLITO S. OLIA, ANA PATIÑO, ROBERTO T. PATIÑO, ANTONIO P. ROCHA, FERNANDO C.
RUFINO, PATERNO P. SAIN, CLAUDIO S. SAYSON, and JOEMARIE VIBO, Petitioners, vs.
DEPARTMENT OF AGRARIAN REFORM and HACIENDA MARIA, INC., Respondents
(G.R. No. 159674 June 30, 2006)

FACTS OF THE CASE:

Hacienda Maria authorities granted by the government a certain parcel of land through a sales
patent. Later on, the said authorities deforested trees over such land and permitted the
petitioners to live and cultivate the land. After the promulgation of Presidential Decree No. 27,
the Hacienda corporation acted upon the agrarian reform that the subject land is undergone to
Operation Land Transfer to which Transfer Certificate of Titles and Emancipation Patent was
later on granted in favor of the petitioners. Several years later, the corporation filed to the
provincial agrarian office an action for the cancellation of the certificate of titles for which there
was no payment of compensation, the lands were not subjected for the cultivation of rice and
corn which the department agreed upon. The Court of Appeals sustained the order against the
petitioners due to procedural matters. Hence, this petition to the Supreme Court.

ISSUES:
Whether the emancipation patents could invalidate or nullify?

HELD:
No, emancipation patents are indefeasible.

The Supreme Court ruled that emancipation patents themselves, like the Certificates of Land
Ownership Award (CLOAs) in Republic Act No. 6657 (the Comprehensive Agrarian Reform Law
of 1988), are enrolled in the Torrens system of registration. The Property Registration Decree in
fact devotes Chapter IX to the subject of EPs. Indeed, such EPs and CLOAs are, in themselves,
entitled to be as indefeasible as certificates of title issued in registration proceedings. Where
land is granted by the government to a private individual, the corresponding patent therefor is
recorded, and the certificate of title is issued to the grantee; thereafter, the land is
automatically brought within the operation of the Land Registration Act, the title issued to the
grantee becoming entitled to all the safeguards provided in Section 38 of the said Act. In other
words, upon expiration of one year from its issuance, the certificate of title shall become
irrevocable and indefeasible like a certificate issued in a registration proceeding.

In this case, the Hacienda authorities allowed the petitioners to cultivate the land and able to
participate in the registration procedure in favor of the petitioners and hence, there is no
reason as also protected under Section 38 of the Land Registration Act that those EP’s and TCT’s
shall be invalidated. The Supreme Court reversed the decision and upheld that the
emancipation patents and the transfer certificate of titles were valid and existing.