Artates vs. Urbi
37 SCRA 395
January 1971
FACTS:
In September 1952, the proper land authorities issued in favor of herein appellant Lino Artates and Manuela Pojas (spouses Artates) a homestead which is covered by Patent No. V-12775 and duly registered in their names (OCT No. P-572). In October 1955, Lino Artates inflicted injuries upon herein defendant Daniel Urbi who then filed Civil Case No. 40 against the former. The Justice of the Peace of Court of the CFI of Camilaniugan, Cagayan, awarded damages in favor of Urbi in the amount of P1,476.35, so in June 1962, the Provincial Sheriff of Cagayan made a public sale of the homestead to satisfy the said judgment.
The spouses Artates alleged that the sale of the homestead to satisfy Lino Artates’ indebtedness accrued in October 1955 violated the provision of the Public Land Law exempting said property from execution for any debt contracted within five years from the date of the issuance of the patent, and that Urbi executed a deed of sale of the same parcel of land in June 1961 for the sum of P2,676.35 to herein defendant Crisanto Soliven, who was a minor, to defraud them.
In March 1953, the CFI of Camilaniugan, Cagayan, upheld the execution made by the Provincial Sheriff upon the homestead, and at declared null and void the sale of the land between Urbi and Soliven.
ISSUE:
Do the appellants spouses Artates possess absolute ownership over the homestead which is covered by a patent?
COURT RULING:
The Supreme Court reversed the decision appealed from and declared the spouses Artates to be entitled to the return and possession of the subject land without prejudice to their continuing obligation to pay the judgment debt, and expenses connected therewith.
Considering the protective policy of the law, the Supreme Court reiterated that the Philippines’ public land laws, being copied from American legislation, resort to American precedents which held that the exemption from "debts contracted" by a homesteader include freedom from money liabilities, from torts or crimes committed by him, such as from bigamy or slander, breach of contract or other torts.
