Silvestre Corpuz v. Republic of the Philippines

Summary

The Supreme Court affirmed the Court of Appeals decision ordering reversion of land covered by free patents to public domain. Silvestre Corpuz obtained free patents in 1978 for lots later discovered to be within the dried riverbed of Irene River. The DENR found the patents were obtained through misrepresentation since Silvestre failed to disclose the riverbed location in his application. Under Section 91 of the Public Land Act, false statements or omissions in patent applications result in ipso facto cancellation. The Court ruled that dried riverbeds remain part of public domain under Article 502(1) of the Civil Code unless expressly converted by law. Evelyn Corpuz, as Silvestre's successor-in-interest, was deemed a necessary party for complete settlement of the reversion claims despite having transferred the property to a third party.