Petitioner
Domingo T. Mendoza
Respondent
Maria Mendoza Navarette
Citation
G.R. No. 82531
Court
Supreme Court
Division
Third Division
Ponente
Davide, Jr., J.
Decided
September 30, 1992

Summary

This case involves a property dispute over inherited land that was fraudulently titled through a free patent. After Teodoro Mendoza's death in 1952, his heirs executed an extrajudicial settlement in 1963 dividing the property, with daughter Maria waiving her rights. In 1974, Maria's husband Leoncio fraudulently obtained a free patent and title over the entire property, including the 3/4 portion belonging to son Domingo. The Supreme Court ruled that a free patent issued over private land is null and void, and that the true owner's action to quiet title is imprescriptible. The Court clarified that the case did not involve co-ownership since it was already terminated by the 1963 settlement, making prescription rules among co-owners inapplicable. The decision protects the rights of true landowners against fraudulent land registration.

Statutes applied

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By the Intellegal Editorial Board · September 30, 1992

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