NatRes Cases 1

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Read/Study the following cases:

1. Bartolata vs. Republic, June 7, 2017, G.R. No. 223334

RA 730 was crafted as an exception to Secs. 6124 and 6725 of CA 141. These provisions govern
the mode of disposition of the alienable public lands enumerated under Sec. 59 of the same law.

2. Heirs of Ramos vs. Heirs of Frando, G.R. No. 149117, December 16, 2004

Acquisition of Public Land Through a Sales Patent; Disposal of public agricultural land through a
sales patent, as in the instant case, is governed by Commonwealth Act No. 141, the Public Land
Act.

3. Metropolitan Bank and Trust Co. vs. Viray, G.R. No. 162218        February 25, 2010

No alienation, transfer, or conveyance of any homestead after five years and before twenty-five
years after issuance of title shall be valid without the approval of the Secretary of Agriculture and
Natural Resources, which approval shall not be denied except on constitutional and legal grounds.

4. Republic vs CA, et al, G.R. No. L-60169 March 23, 1990

A certificate of title that is void may be ordered cancelled. A title will be considered void if it is
procured through fraud, as when a person applies for registration of the land under his name
although the property belongs to another. In the case of disposable public lands, failure on the part
of the grantee to comply with the conditions imposed by law is a ground for holding such title void.
The lapse of the one year period within which a decree of title may be reopened for fraud would not
prevent the cancellation thereof, for to hold that a title may become indefeasible by registration, even
if such title had been secured through fraud or in violation of the law, would be the height of
absurdity. Registration should not be a shield of fraud in securing title.

5.Republic vs. Dayaoen, G.R. No. 200773        July 8, 2015

Requisites for the filing of an application for registration of title under Section 14 (1)

6.Republic vs. Ravelo, G.R. No. 165114       August 6, 2008

Under Section 91 of CA No. 141, the "statements made in application shall be considered essential
conditions and parts of any concession, title or permit issued on the basis of such application, and
any false statement therein or omission of facts altering or changing or modifying the consideration
of the facts set forth in such statements . . . shall ipso facto produce the cancellation of the
concession, title, or permit granted." 

7.Republic vs. Spouses Alforte, GR 217051, August 22, 2018

Jurisprudence settles that one of the reservations and conditions under the Original Certificate of
Title of land granted by free patent is that the said land is subject 'to all conditions and public
easements and servitudes recognized and prescribed by law especially those mentioned in Sections
109, 110, 111, 112, 113 and 114, Commonwealth Act No. 141, as amended' Section 112 ofC.A. No.
141, as amended, provides that lands granted by patent shall be subjected to a right-of-way in favor
of the Government.

8.Republic vs. Lee Tsai, G.R. No. 168184        June 22, 2009

On Section 48(b) of CA 141, as amended by PD 1073.; proof of possession

9.Republic vs. Spouses Regulto, April 18, 2016, G.R. No. 202051

Section 112 of CA 141 in relation to Section 5 of the IRR of R.A. No. 8974

10.Sta. Ignacia Rural Bank vs. CA, G.R. No. 97872 March 1, 1994

Right to repurchase free patent land

11.Taar et al vs. Lawan et al, October 11, 2017, G.R. No. 190922

On Sections 11, 44, 91 and Section 101 of the Public Land Act. Section 101 clearly states:

SEC. 101. All actions for the reversion to the Government of lands of the public domain or
improvements thereon shall be instituted by the Solicitor General or the officer acting in his stead, in
the proper courts, in the name of the Republic of the Philippines.

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