Petitioner
Gloria A. Ferrer
Respondent
Hon. Antonio Bautista
Citation
G.R. No. 46963
Court
Supreme Court
Division
Third Division
Ponente
Vitug, J.
Decided
March 14, 1994

Summary

This case involves a property dispute over a strip of land south of Lot 1980 in Aringay, La Union. Petitioner Gloria Ferrer claimed ownership by accretion as owner of adjacent Lot 1980, while respondents claimed ownership through Free Patent No. 309504 and Certificate of Title No. P-168 issued in 1966. The trial court dismissed petitioner's quieting of title action, finding it was a collateral attack on the free patent. The Supreme Court reversed, ruling that petitioner lawfully owns the land by accretion under Article 457 of the Civil Code. The Court found the free patent null and void since the Director of Lands lacked authority to grant patents over land already in private ownership. The decision establishes that actions to declare void titles do not prescribe and can be attacked both directly and collaterally, ultimately ordering reconveyance to the rightful owner.

Statutes applied

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By the Intellegal Editorial Board · March 14, 1994

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