Cancelling The Sale Certificates And/Or Transfer Certificates Of Title Numbers 62603, 62604, And 62605, Covering Lots 1, 2, And 3, Respectively, PCS-4383, All In The Name Of Carmel Farms, I

Case Overview and Summary

Summary of Presidential Decree No. 293

Cancellation of Sale Certificates and Transfer Certificates of Title:
- Cancels Sale Certificates and/or Transfer Certificates of Title Numbers 62603, 62604, and 62605, covering Lots 1, 2, and 3, respectively, PCS-4383, all in the name of Carmel Farms, Inc., which is a consolidation and subdivision of Lots 979, 981, 982, 985, 988, 989, 990, 991-NEW, 1226, 1230, and 980-C-2 (LRC PSD-1730), all of Tala Estate, Caloocan City.

Background:
- Employees of the Office of the President of the Philippines and personnel of the Presidential Guard Battalion, including their families, were ordered to vacate Malacañang Park.
- These families formed the Malacañang Homeowners Association, Inc. and transferred their dwellings to the vicinity of the Tala Estate in October 1972, believing the land was available for disposition and sale to them.

Illegal Issuance of Certificates:
- The land is being claimed by Carmel Farms, Inc. based on alleged Sale Certificates and/or Transfer Certificates of Title issued in its favor.
- These certificates were discovered to have been illegally issued, contrary to the provisions of Act 1120 (Friar Lands Act), due to non-payment of consideration and encroachment upon property of the Republic of the Philippines.

Tala Estate and Friar Lands Act:
- The land was formerly part of the Tala Estate, the disposition of which is subject to the provisions of the Friar Lands Act.
- Under Section 15 of the Friar Lands Act, title to each parcel of land sold is reserved to the Government until full payment of all installments of purchase money and interest by the purchaser.
- Neither the original purchasers nor their subsequent transferees have made full payment for the lots claimed by Carmel Farms, Inc., including those on which the dwellings of the Malacañang Homeowners Association members stand.

Disposition of Land:
- The land occupied by the members of the Malacañang Homeowners Association has never ceased to form part of the property of the Republic of the Philippines.
- Any acts affecting the land and purporting to segregate it from the property of the Republic are null and void ab initio as against the law and public policy.
- The land is declared open for disposition and sale to the members of the Malacañang Homeowners Association, Inc., the present bona fide occupants, pursuant to Commonwealth Act No. 32, as amended.

Policy:
- It has been the firm policy of the Government to provide opportunity for the landless and homeless to acquire residential lots.