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    Ramos-Balaio vs. Ramos

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    Frnz Fernandez
    This case discusses a dispute over ownership of a parcel of land between the children of the original occupants and others who later claimed rights to the land. The Supreme Court ultimately ruled that none of the parties obtained a valid title to the land, so it remained part of the public domain belonging to the State.

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    © All Rights Reserved
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    Ramos-Balaio vs. Ramos

    Uploaded by

    Frnz Fernandez
    15 views2 pages
    This case discusses a dispute over ownership of a parcel of land between the children of the original occupants and others who later claimed rights to the land. The Supreme Court ultimately ruled that none of the parties obtained a valid title to the land, so it remained part of the public domain belonging to the State.

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    © © All Rights Reserved

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    This case discusses a dispute over ownership of a parcel of land between the children of the original occupants and others who later claimed rights to the land. The Supreme Court ultimately ruled that none of the parties obtained a valid title to the land, so it remained part of the public domain belonging to the State.

    Copyright:

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

    Ramos-Balaio vs. Ramos

    Uploaded by

    Frnz Fernandez
    This case discusses a dispute over ownership of a parcel of land between the children of the original occupants and others who later claimed rights to the land. The Supreme Court ultimately ruled that none of the parties obtained a valid title to the land, so it remained part of the public domain belonging to the State.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    40. Ramos-Balaio vs.

    Ramos
    G.R. No. 168464
    January 23, 2006

    Facts:

    Petitioner Zenaida and her brother Alexander (now deceased) are the children of spouses
    Susana Bueno and Abundio Ramos. The spouses started occupying Lot No. 204 in 1938.
    Abundio died in 1944. Susana met her second husband, respondent Eusebio Ramos in 1946,
    with whom she had five children, one of whom is respondent Rolando.

    It was alleged that as Susana accompanied her husband Eusebio, a soldier, wherever he was
    assigned, Susana’s father, George Bueno, and daughter, petitioner Zenaida continued the
    cultivation and possession of the subject land. Sometime later, Susana sold the land to
    petitioner who, in turn, partitioned it among herself, her brother, Alexander, and respondent
    Rolando and his siblings. The partition was not registered but Deeds of Sale were executed in
    favor of Rolando and Alexander.

    Petitioner thereafter mortgaged her share; however, it came to her knowledge that respondents
    Rolando and Eusebio had usurped her share and deprived the mortgagees of possession over
    the land. After settling the mortgage, petitioner filed a case for recovery of inheritance,
    possession and damages with a petition for preliminary mandatory injunction.

    The trial court rendered its decision holding that petitioner was deprived of her right to cultivation
    and possession of her share of Lot No. 204.

    On appeal, the Court of Appeals found that neither Zenaida nor Alexander complied with the
    homestead application requirements in order to acquire superior vested right. As a
    consequence, it reversed the decision of the trial court.

    Issue:

    WON the subject land remains part to be part of the public domain and rightfully belongs to the
    State.

    Ruling:

    YES. Zenaida’s argument is flawed because it assumes that her parents had perfected their title
    over the land and that they could validly convey the same to third persons, whether by sale or
    by inheritance. However, a careful examination of the records shows that petitioner has not
    satisfactorily established that a valid application for homestead patent was filed by her parents.

    The purported sale, therefore, between petitioner and her mother cannot be given effect, nor
    can it be a source of right for Zenaida, because Susana did not have the authority to sell what
    did not belong to her. The invalidation of the sale consequently nullifies the partition of the
    property among Zenaida, Alexander, and Rolando and his siblings because Zenaida could not
    have disposed of the land which she did not own.

    For the same reason, neither Eusebio nor Rolando can claim any right whatsoever as heirs of
    Susana. Their claim evidently relies on Section 105 of the Public Land Act. The reliance is
    misplaced because the cited provision speaks of an applicant, grantee, or lessee. Susana was
    not one of these. In her lifetime, despite her possession and cultivation of the land, she failed to
    apply for a homestead patent and to acquire any vested right that Eusebio or Rolando can
    inherit. As such, the land remains part of the public domain.

    Hence, the subject land remains to be part of the public domain and rightfully belongs to the
    State. As held by the Court of Appeals, none of the parties obtained a defensible title to the
    property which can be upheld by the Court.

    Notes:

    1. Under the Regalian doctrine, all lands of the public domain belong to the State and those
    lands not appearing to be clearly within private ownership are presumed to belong to the State.
    Lands of the public domain are classified into agricultural, forest or timber, mineral lands, and
    national parks. Alienable lands of the public domain shall be limited to agricultural lands.

    2. Commonwealth Act No. 141 (1936), or the Public Land Act, as amended by Presidential
    Decree No. 1073 (1977), remains to be the general law governing the classification and
    disposition of alienable lands of the public domain. It enumerates the different modes of
    acquisition of these lands and prescribes the terms and conditions to enable private persons to
    perfect their title to them. It is, therefore, the applicable law to the case before us.

    3. A homestead patent, such as the subject of the instant case, is one of the modes to acquire
    title to public lands suitable for agricultural purposes. Under the Public Land Act, a homestead
    patent is one issued to any citizen of this country, over the age of 18 years or the head of a
    family, and who is not the owner of more than 24 hectares of land in the country. To be
    qualified, the applicant must show that he has resided continuously for at least one year in the
    municipality where the land is situated and must have cultivated at least one-fifth of the land
    applied for.

    4. Section 105. If at any time the applicant or grantee shall die before the issuance of the patent
    or the final grant of the land, or during the life of the lease, or while the applicant or grantee still
    has obligations pending towards the Government, in accordance with this Act, he shall be
    succeeded in his rights and obligations with respect to the land applied for or granted or
    leased under this Act by his heirs in law, who shall be entitled to have issued to them the patent
    or final concession if they show that they have complied with the requirements therefor,
    and who shall be subrogated in all his rights and obligations for the purposes of this Act.

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