GR No.

L-19615
December 24, 1964

In Matter of the Application fro the registration of land, Leonor De Los Angeles, Federico De Los
Angeles, et al., applicants-appellants
Vs
Isidro Santos, Antonio Astudillo, et al., Director of Lands and the Province of Rizal, oppositors-
appellees

Facts:
1. November 21, 1959
- There was an application for registration of title of 12 parcels of land in Ampid San Mateo
Rizal.
- The application was made by the applicant-appellant Leonor De Los Angeles and other co-
applicants alleging that they are “owners pro-indiviso1 and in fee simple of the
aforementioned land. Date was set on May 1960 for the initial hearing.
2. March 1960
- The Director of lands opposed the application for registration stating that the land is a
“portion of public domain”
3. May 1960
- Province of Rizal also opposed on the reason that there was a required 3.00 meter strips of
public easement in lots along Ampid river and creek.
- At the initial hearing in the land registration court, an order of general default2 was issued
except against the Director of lands, the Province of Rizal and 11 oppositors
4. July 1960
- Private oppositors filed their written opposition claiming that they are the “lawful owners”
owners of the lands “for having acquired homestead patents3 over said lots”
5. 1961
- A “Report” was filed by the Land Registration Commissioner stating that Lot 11 is a portion
previously patented on June 12, 1961 in the name of Julio Hidalgo
- The court then required the applicants to show cause why their application should not be
dismissed as to Lot11
- The court later on issued an order dismissing the application of De los Angeles et al with
respect to lot 11
6. Applicants appealed to the Supreme Court

Issue: W/N a land registration court which has validly acquired jurisdiction over a parcel of land for
registration of title thereto could be divested of said jurisdiction by a subsequent administrative act
consisting in the issuance by the Director of Lands of a homestead patent covering the same parcel of land
(Lot 11)

1
Common property; when 2 or more proprietors has an absolute and unrestricted right to a fractional share of a
property
2
Order of general default – if no person appears and answers within the time allowed; a party declared in default
loses his standing in court
3
A homestead patent, one registered under the Land registration act, becomes indefeasible as a Torrens title
Held:
1. Director of Land’s jurisdiction, administrative supervision and executive control cover only lands
of public domain and not to lands already privately owned.
- A homestead patent issued by him over a land not of the public domain is null and without
force and effect against the owner.
- In the land registration proceedings, applicants contend that as of November 21, 1959 they
were already “owners pro-indiviso and in fee simple of the aforesaid land”
 If applicants successfully prove their claim, Julio Hidalgo’s homestead patent is no
longer public therefore becomes a nullity
 Applicants should be given opportunity to prove registrable title to Lot 11