Section 103. Certificates of title pursuant to patents. Whenever public land is by the Government alienated, granted or conveyed to any person, the same shall be brought forthwith under the operation of this Decree. It shall be the DUTY OF THE OFFICIAL ISSUING THE INSTRUMENT OF ALIENATION, GRANT, PATENT OR CONVEYANCE IN BEHALF OF THE GOVERNMENT TO CAUSE SUCH INSTRUMENT TO BE FILED WITH THE REGISTER OF DEEDS OF THE PROVINCE OR CITY WHERE THE LAND LIES, and to be there registered like other deeds and conveyance, whereupon a certificate of title shall be entered as in other cases of registered land, and an owner's duplicate issued to the grantee. The deed, grant, patent or instrument of conveyance from the Government to the grantee shall not take effect as a conveyance or bind the land but shall operate only as a contract between the Government and the grantee and as evidence of authority to the Register of Deeds to make registration. It is the act of registration that shall be the operative act to affect and convey the land, and in all cases under this Decree, registration shall be made in the office of the Register of Deeds of the province or city where the land lies. The fees for registration shall be paid by the grantee. After due registration and issuance of the certificate of title, such land shall be deemed to be registered land to all intents and purposes under this Decree.


> The instruments mentioned in this section whereby public lands are alienated, granted or conveyed are instruments transferring ownership and not just mere documents of lease or transferring mere possession

> Provision directs the issuance to the grantee of an owner’s duplicate certificate

> After due registration and issuance of the certificate of title, the land shall be deemed registered land for all intents and purposes under the Property Registration Decree

> Public land patents when duly registered are veritable Torrens title subject to no encumberances except those stated therein, and those specified by the statute.

> They become private property which can no longer be the subject of subsequent disposition by the Director of Lands

> Where disposable public land is granted by the government by virtue of a public land patent, the patent is recorded and the corresponding certificate of title is issued to the grantee, thereafter, the land is automatically brought within the operation of PD1529, entitled to all the safeguards of a veritable Torrens
title. Upon the expiration of 1 year from its issuance, the certificate of title shall become irrevocable and indefeasible like a certificate issued in a registration proceeding

> A certificate of title issued pursuant to a patent has the force and effect of a torrens title issued through judicial registration proceedings

> But a land registration court which has validly acquired jurisdiction over a parcel of land for registration of title cannot 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