Title
Arbias vs. Republic
Case
G.R. No. 173808
Decision Date
Sep 17, 2008
Fernanda Arbias sought land registration, but the Supreme Court denied her petition, citing insufficient proof of possession and alienable land classification, upholding the Regalian Doctrine.

Case Digest (G.R. No. 173808)
Expanded Legal Reasoning Model

Facts:

  • Procedural Background
    • Fernanda Arbias, the petitioner, filed a Petition for Review on Certiorari challenging the decisions of the Court of Appeals.
    • The appeal sought to annul the CA Decision (dated 2 September 2005) which reversed the Regional Trial Court’s decision dated 26 June 2000, where petitioner was granted her application for registration of title under PD No. 1529.
    • Additionally, petitioner contested a CA Resolution (dated 19 July 2006) denying her Motion for Reconsideration.
  • Factual Antecedents and Transactional Events
    • On 12 March 1993, Lourdes T. Jardeleza executed a Deed of Absolute Sale selling an unregistered parcel of land (Cadastral Lot No. 287, Estancia Cadastre) situated in Poblacion, Estancia, Iloilo, for P33,000.00 to Fernanda Arbias, who is married to Jimmy Arbias.
    • The subject property, described as a residential lot of about 600 square meters, became the subject of dispute due to conflicting area measurements between the Deed of Sale, tax declarations, and the cadastral survey (which indicated 717 square meters).
  • Registration Application and Court Proceedings
    • Petitioner filed a verified Application for Registration of Title with the RTC on 17 June 1996 (LRC Case No. N-1025).
      • Documentary evidence attached included the Deed of Absolute Sale, a tracing cloth with blue print copies, Surveyor’s Certification, Technical Description, and tax declarations.
    • The RTC forwarded the application and accompanying documents to the Land Registration Authority (LRA), which later confirmed petitioner’s compliance with the requirements antecedent to publication.
    • The RTC conducted hearings beginning with an initial notice for the hearing on 17 February 1999 and a rescheduled hearing on 23 July 1999 after an Opposition was filed by the respondent (represented initially by the City Prosecutor deputized by the Office of the Solicitor General).
  • Evidence and Testimonies Presented
    • During the 23 July 1999 hearing, petitioner testified regarding her purchase, acts of ownership, and possession over the subject property.
      • Petitioner introduced documentary exhibits including tax declarations and a survey plan.
      • Testimony from adjoining lot owners provided mixed evidence regarding the boundaries and area of the property.
    • The respondent, through the City Prosecutor, reiterated objections centered on the discrepancy in the property area and the alleged insufficiency of proof of open, continuous, exclusive, and notorious possession on the part of petitioner.
  • Trial Court and Appellate Court Decisions
    • On 26 June 2000, the RTC ruled in favor of petitioner granting the registration based on:
      • Petitioner’s claim as a purchaser in good faith supported by documentary exhibits and her continuous possession, even though challenges regarding the adequacy of evidence (muniments of title, tax declarations) were noted.
      • The assertion of adverse, open, continuous, and exclusive possession starting from 1992, evolving into an incontrovertible proof of ownership.
    • The respondent, via the Office of the Solicitor General (OSG), appealed the RTC decision.
      • In its CA Brief, the respondent questioned the trial court’s reliance on certain evidences such as the approved survey plan and the purported continuous possession of petitioner.
    • On 2 September 2005, the Court of Appeals reversed the RTC decision and dismissed petitioner’s application for registration.
      • The CA acknowledged the equivalence of the blueprint certification to the LMB’s approval and dismissed the defects on notice publication and land area discrepancy as non-fundamental.
      • However, the CA digressed on the issue of possession by noting the lack of independent corroborative evidence beyond petitioner’s own assertions.
    • Petitioner’s motion for reconsideration was denied by a CA Resolution dated 19 July 2006.
  • Key Disputed Facts
    • The duration and nature of possession:
      • Petitioner asserted possession in the concept of an owner extending allegedly from 30 years ago through her predecessor and continuing after her purchase.
      • Her testimony during trial, however, admitted that her personal possession amounted to nearly six years only, with no other substantial evidence showing the requisite period of possession under a bona fide claim.
    • Classification of the subject property:
      • Petitioner relied on a survey plan notation and previous tax declarations to assert that the property was alienable and disposable.
      • The CA, supported by prior jurisprudence, held that such annotations by a surveyor and the mere presentation of tax documents do not provide conclusive evidence to overcome the presumption of State ownership under the Regalian doctrine.

Issues:

  • Whether the Office of the Solicitor General is estopped from assailing the decision of the RTC on the ground that it did not object to petitioner’s evidence during the trial.
    • The petitioner contended that the OSG should be barred from challenging the RTC decision because there was no timely and proper presentation of contrary evidence.
  • Whether the Court of Appeals erred in giving less weight to the RTC’s conclusions regarding the demeanor and evidence of the witness, particularly when the OSG failed to present substantial evidence at the trial level.
    • Petitioner argued that the trial court was in the best position to assess the witness’ credibility and the conclusive nature of the proofs presented.
  • Whether the Court of Appeals incorrectly held that the subject property remains public land despite petitioner’s contention that her and her predecessors’ possession for more than 30 years should have converted its status to alienable and disposable.
    • The petitioner maintained that continuous possession should be conclusive evidence to reclassify the land away from its regalian status.
  • Whether the Court of Appeals committed error in dismissing petitioner’s application outright instead of remanding the case to the RTC for further proceedings in light of precedents such as Abaoag v. Director of Lands and Republic v. Sayo.
    • The petitioner argued that, on the basis of these precedents, a remand would have been appropriate to fully evaluate her evidence of possession and the consequent claim for title registration.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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