Republic v. Court of First Instance of Lanao del Norte
REITERATIONFacts
The Antecedents: Private respondent Alejo Villaros was issued Homestead Patent No. 51621 covering 5.509 hectares of land, and subsequently, Original Certificate of Title No. 917. Within a year of issuance, Villaros sold the property to Marta Roxas. Procedural History: The Republic of the Philippines, represented by the Solicitor General, filed a complaint for reversion before the Court of First Instance of Lanao del Norte (Civil Case No. 1382). The complaint alleged that the sale violated Section 118 of the Public Land Act, rendering it null and void and causing the reversion of the property to the State. Private respondent Villaros moved to dismiss the complaint, arguing that the cause of action was barred by laches, estoppel, and prescription. The respondent court dismissed the complaint, finding that the action was filed 11 years and 6 months after the cause of action accrued, thus barred by prescription. The Petition: The Republic filed a petition for review on certiorari, assailing the dismissal of its complaint, arguing that the State, in suing for reversion, was not acting in its sovereign capacity but as a private individual seeking to recover patrimonial property.
Issue(s)
Whether the respondent court erred in holding that the action for reversion filed by the Republic of the Philippines is barred by prescription. Whether the State, in an action for reversion of a homestead patent, acts in its sovereign capacity or as a private individual.
Ruling
The orders of the respondent court dismissing the complaint for reversion and denying the motion for reconsideration are SET ASIDE and REVERSED. The respondent court is ORDERED to take further proceedings in the case.
Ratio Decidendi
On the issue of prescription and the State's capacity to sue: The appeal has merit because the statute of limitations does not lie against the State. Civil Case No. 1382, an action for reversion, was brought by the petitioner Republic of the Philippines in its capacity as a sovereign state. Section 118 of Commonwealth Act No. 141 explicitly states that any transfer or alienation of a homestead grant within five (5) years from the issuance of the patent is null and void and constitutes a cause for the reversion of the homestead to the State. The government's right to bring an appropriate action for reconveyance is not barred by the lapse of time; the Statute of Limitations does not run against the State. This principle was reiterated in previous rulings, emphasizing that even if the property has been brought under the Torrens System, the Court may properly order its reconveyance to the grantor if the grantee is found not entitled to hold the land in fee simple due to violations of the Public Land Law. Therefore, the dismissal of the complaint on the ground of prescription was erroneous. The provided ratio already addresses both issues, as the State acts in its sovereign capacity when pursuing reversion, and in that capacity, prescription does not run against it. Therefore, no additional ratio is needed.
Main Doctrine
The statute of limitations does not run against the State, and the government's right to bring an action for reconveyance of a homestead granted under the Public Land Act, which was illegally alienated within the prohibited period, is not barred by the lapse of time.