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    De Los Angeles Vs Santos

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    emem
    Leonor de los Angeles and others filed an application to register title to 12 parcels of land, including Lot 11. The Director of Lands and private parties opposed, claiming some of the land was public domain or they held homestead patents. A report recommended dismissing Lot 11 as it was previously patented to Julio Hidalgo. The court dismissed Lot 11. The applicants appealed, arguing the lower court erred by dismissing Lot 11 after a homestead patent was issued during the registration process. The Supreme Court ruled that a land registration court does not lose jurisdiction over a parcel by a subsequent administrative act like a homestead patent. If the applicants can prove registrable title, the homestead patent would be declared null. As registration proceedings determine

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    De Los Angeles Vs Santos

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    emem
    432 views2 pages
    Leonor de los Angeles and others filed an application to register title to 12 parcels of land, including Lot 11. The Director of Lands and private parties opposed, claiming some of the land was public domain or they held homestead patents. A report recommended dismissing Lot 11 as it was previously patented to Julio Hidalgo. The court dismissed Lot 11. The applicants appealed, arguing the lower court erred by dismissing Lot 11 after a homestead patent was issued during the registration process. The Supreme Court ruled that a land registration court does not lose jurisdiction over a parcel by a subsequent administrative act like a homestead patent. If the applicants can prove registrable title, the homestead patent would be declared null. As registration proceedings determine

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    De Los Angeles vs Santos

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    Leonor de los Angeles and others filed an application to register title to 12 parcels of land, including Lot 11. The Director of Lands and private parties opposed, claiming some of the land was public domain or they held homestead patents. A report recommended dismissing Lot 11 as it was previously patented to Julio Hidalgo. The court dismissed Lot 11. The applicants appealed, arguing the lower court erred by dismissing Lot 11 after a homestead patent was issued during the registration process. The Supreme Court ruled that a land registration court does not lose jurisdiction over a parcel by a subsequent administrative act like a homestead patent. If the applicants can prove registrable title, the homestead patent would be declared null. As registration proceedings determine

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    432 views2 pages

    De Los Angeles Vs Santos

    Uploaded by

    emem
    Leonor de los Angeles and others filed an application to register title to 12 parcels of land, including Lot 11. The Director of Lands and private parties opposed, claiming some of the land was public domain or they held homestead patents. A report recommended dismissing Lot 11 as it was previously patented to Julio Hidalgo. The court dismissed Lot 11. The applicants appealed, arguing the lower court erred by dismissing Lot 11 after a homestead patent was issued during the registration process. The Supreme Court ruled that a land registration court does not lose jurisdiction over a parcel by a subsequent administrative act like a homestead patent. If the applicants can prove registrable title, the homestead patent would be declared null. As registration proceedings determine

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    In the matter of the application for registration of land.

    Leonor de los Angeles, et al.


    vs
    Isidoro O. Santos, Antonio Astudillo, et al., the Director of Lands and the
    Provice of Rizal
    G.R. No. L-19615 December 24, 1964
    Facts:
    Leonor de los Angeles and seven co-applicants filed an application for registration of
    title to 12 parcels of land in Ampid San Mateo Rizal. They alleged that they were
    owners pro-indiviso and in fee simple of the aforesaid land. Subsequently, the
    Director of Lands filed an opposition stating that the land is a portion of the public
    domain while other private oppositors filed their written opposition claiming they
    are the lawful owners of the parcels of land in question for having acquired
    homestead patents over said lots.
    A report filed in court by the Land Registration Commissioner stated that the parcel
    of land described as Lot 11, applied for in the same case, is a portion of a previously
    patented land awarded to one of the oppositors (Julio Hidalgo) and recommended
    that the case be dismissed with respect to Lot 11, giving due course, however, to
    the other lots in the application.
    The court required the applicants to show cause why their application should not be
    dismissed as to Lot 11 to which the applicants filed an opposition to motion to
    dismiss. However, the court issued an order dismissing the application with respect
    to Lot 11. The applicants filed a motion for reconsideration but were denied, hence,
    this appeal. They alleged that the lower court erred in dismissing the application for
    the registration as regards to Lot 11, over which a homestead patent was issued by
    the Director of Lands during the pendency of the registration proceeding.
    Issue:
    Whether a land registration court which has validly acquired jurisdiction over a
    parcel of land for registration of title thereto could be divested of said jurisdiction by
    a subsequent administrative act consisting in the issuance by the Director of Lands
    of a homestead patent covering the same parcel of land
    Ruling:
    It is well settled that the Director of Lands jurisdiction, administrative supervision
    and executive control extend only over lands of the public domain and not to lands
    already of private ownership. Accordingly, a homestead patent issued by him over
    land not of the public domain is a nullity, devoid of force and effect against the
    owner.
    The applicants contended that they were already owners pro-indiviso and in fee
    simple of the aforesaid land when they applied for registration on November 21,
    1959. If they were to successfully prove this and show their alleged registrable title
    to the land, it could only result in the finding that when Julio Hidalgos homestead
    patent was issued over Lot 11 on June 12, 1961 said lot was no longer public. The
    land registration court, in that event, would have to order a decree of title issued in
    applicants favour and declare aforesaid homestead patent a nullity which vested no
    title in the patentee as against the real owners.
    Since the existence or non-existence of applicants registrable title to Lot 11 is
    decisive of the validity or nullity of the homestead patent issued as aforestated on
    said lot the court a quos jurisdiction in the land registration proceedings could not
    have been divested by the homestead patents issuance.
    Further, proceedings for land registration are in rem whereas those for acquisition of
    homestead patent are not. A homestead patent, therefore, does not finally dispose
    of the public or private character of the land as far as courts upon in rem are
    concerned. The applicants should thus be given opportunity to prove registrable
    title to Lot 11.

    The case is remanded to the court a quo for further proceedings.

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