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Republic v.

Mangotara
Same; Reversion; Regalian Doctrine; Words and Phrases; Reversion is an action
where the ultimate relief sought is to revert the land back to the government under
the Regalian doctrine; The right of the Republic to institute an action for reversion is
rooted in the Regalian doctrine.
Same; Same; Same; Just because Original Certificates of Title (OCTs) were already
issued in a private persons name does not bar the Republic from instituting an
action for reversion.
Reversion; Prescription; Elementary is the rule that prescription does not run against
the State and its subdivisions; The right of reversion or reconveyance to the State is
not barred by prescription.
FACTS: As a result of the 1997 Cacho case, the decrees of registration were reissued bearing new numbers and OCTs were issued for the two parcels of land in
Doa Demetrias name.
The dispute over Lots 1 and 2 did not end with the termination of the 1997 Cacho
case. Another four cases involving the same parcels of land were instituted before
the trial courts during and after the pendency of the 1997 Cacho case. These cases
are: Expropriation Case, Quieting of Title Case, Ejectment or Unlawful Detainer
Case, Cancellation of Titles and Reversion Case.
The Cancellation of Titles and Reversion Case:
On October 13, 2004, the Republic filed a Complaint for the Cancellation of OCT and
Reversion against the late Doa Demetria, represented by her alleged heirs, Vidal
and/or Teofilo, together with AZIMUTH and LANDTRADE.
On October 15, 1998, Original Certificates of Title were issued in the name of
Demetria Cacho, widow, now deceased consisting of a total area of Three
Hundred Seventy-Eight Thousand Seven Hundred and Seven (378,707) square
meters and Three Thousand Seven Hundred Thirty-Five (3,635) square meters,
respectively, situated in Iligan City.
The afore-stated titles were issued in implementation of a decision rendered in
Cacho v. Government of the United States.
The RTC-Branch 4 likewise held that the Republic failed to state a cause of action in
its Complaint. The arguments of the Republici.e., the absence of a new survey
plan and deed, the titles covered properties with much larger area than that
granted by the LRChad been answered squarely in the 1997 Cacho case. Also, the
Complaint failed to allege that fraud had been committed in having the titles
registered and that the Director of Lands requested the reversion of the subject
parcels of land.
ISSUE: Whether or not the Republics Complaint for Reversion will prosper
HELD: Reversion is an action where the ultimate relief sought is to revert the land
back to the government under the Regalian doctrine. Considering that the land

subject of the action originated from a grant by the government, its cancellation is a
matter between the grantor and the grantee.134 In Estate of the Late Jesus S.
Yujuico v. Republic135 (Yujuico case), reversion was defined as an action which
seeks to restore public land fraudulently awarded and disposed of to private
individuals or corporations to the mass of public domain. It bears to point out,
though, that the Court also allowed the resort by the Government to actions for
reversion to cancel titles that were void for reasons other than fraud.
The reversion case of the Republic rests on the main argument that the OCTs
issued in Doa Demetrias name, included parcels of lands which were not
adjudicated to her by the Court in the 1914 Cacho case.
Just because OCTs were already issued in Doa Demetrias name does not bar the
Republic from instituting an action for reversion. Indeed, the Court made it clear in
Francisco v. Rodriguez that Section 101 of the Public Land Act may be invoked only
when title has already vested in the individual, e.g., when a patent or a certificate of
title has already been issued[,] for the basic premise in an action for reversion is
that the certificate of title fraudulently or unlawfully included land of the public
domain, hence, calling for the cancellation of said certificate. It is actually the
issuance of such a certificate of title which constitutes the third element of a cause
of action for reversion.
The Court further finds that the Complaint of the Republic in Civil Case No. 6686
sufficiently states a cause of action for reversion, even though it does not allege
that fraud was committed in the registration or that the Director of Lands requested
the reversion.
The other contention that the Complaint in Civil Case No. 6686 does not allege that
it had been filed by the Office of the Solicitor General (OSG), at the behest of the
Director of Lands, does not call for its dismissal on the ground of failure to state a
cause of action. Section 101 of Commonwealth Act No. 141, otherwise known as the
Public Land Act, as amended, simply requires that:
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. (Emphasis supplied.)