Case Digest (G.R. No. 172331)
Facts:
Ramon Aranda v. Republic of the Philippines, G.R. No. 172331, August 24, 2011, the Supreme Court First Division, Villarama, Jr., J., writing for the Court. The petition challenges the Court of Appeals’ Decision dated July 26, 2005 and Resolution dated April 11, 2006 in CA-G.R. CV No. 73067, which reversed the Regional Trial Court of Tanauan, Batangas, Branch 6 (Land Reg. Case No. T-335 / LRA Record No. N-69447) that had ordered original registration in favor of the petitioner.The land in question is a 9,103.47 sq. m. parcel in Barangay San Andres, Malvar, Batangas, designated Lot 3730, Psc 47, Malvar Cadastre. The original petition for judicial confirmation of title was filed in the name of ICTSI Warehousing, Inc. (ICTSI‑WI), represented by Enrique K. Razon, Jr. The Republic, through the Office of the Solicitor General, opposed the petition on the ground that the property is part of the public domain and the applicant had not acquired a registrable title under Commonwealth Act No. 141 as amended by R.A. No. 6940.
ICTSI‑WI later sought leave to amend its petition (citing lack of a certification against forum shopping, reliance on tax-declaration boundaries, and a defective sale), and the trial court admitted an amended application filed in the name of Ramon Aranda (petitioner). Petitioner alternatively invoked Section 48 of Commonwealth Act No. 141, claiming continuous possession in the concept of owner for more than thirty years prior to the filing of the application.
At trial petitioner offered testimonial evidence: his sister Merlita A. Enriquez testified that their father donated the land to petitioner in 1965 and that Ramon tilled the land since then; she said an original donation document had been eaten by rats. Luis Olan testified his father Lucio Olan had owned and farmed the land and sold it to Anatalio Aranda in 1946; he had accompanied his father to the land from childhood. Petitioner also submitted tax declarations and two deeds of confirmation (a 1946 sale confirmation and a 1965 donation confirmation), both executed in 2000.
On January 31, 2001 the RTC (Judge Voltaire Y. Rosales) granted the application and ordered issuance of a decree of registration in petitioner’s favor. The Court of Appeals (A�ssociate Justice Magdangal M. De Leon, with A.J. Salvador J. Valdez, Jr. and A.J. Mariano C. Del Castillo concurring) reversed on July 26, 2005, holding that petitioner failed to prove the required character and duration of possession and that the confirmation documents executed in 2000 were of little evidentiary weight. The CA denied petitioner’s motion for reconsideration by Resolution dated April 11, 2006.
Petitioner filed a petition for review on certiorari under Rule 45 to the Suprem...(Pro-only)
Issues:
- Did petitioner prove that the land applied for is alienable and disposable?
- Did petitioner and his predecessors‑in‑interest establish open, continuous, exclusive and notorious possession in the concept of owner for the period required by law?
- May the deeds of confirmation executed in 2000 and the testimony about lost originals be accepted as competent proof of t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)