Case Digest (G.R. No. 254433)
Facts:
Arlo Aluminum Co., Inc. v. Republic of the Philippines, G.R. No. 254433, April 17, 2024, Supreme Court First Division, Hernando, J., writing for the Court.Petitioner Arlo Aluminum Co., Inc. filed an application on June 21, 2012 for judicial registration of title to Lot Nos. 7948 and 7947 in Barangay Caniogan, Pasig City, claiming acquisition of Lot No. 7948 in 1996 from Melvin Atienza and Lot No. 7947 from Dalisay Crisostomo, both of whom allegedly derived title from Esmeraldo (Esmeralda) Tambongco whose possession dated to June 12, 1945 or earlier. Arlo submitted survey plans, technical descriptions, tax declarations, realty tax clearances and two DENR–NCR certifications dated September 27, 2013 asserting the lots were within alienable and disposable land per LC Map No. 639. The Office of the Solicitor General entered appearance and deputized the City Prosecutor of Pasig to appear for the Republic.
At trial Arlo offered documentary exhibits (Exhibits A–R) and called three witnesses: Rosanna M. Santiago (an Arlo employee authorized to file the application), Ronilo B. Jubacon (longtime Arlo employee and technical officer), and Caronia L. Murcia (DENR records custodian). The public prosecutor declined to present evidence and the case was submitted for decision.
The Regional Trial Court (Branch 152, Pasig City) rendered judgment on July 30, 2018 granting Arlo’s application and ordering a Decree of Registration, finding open, continuous and exclusive possession since before 1945. The Republic, through the OSG, filed a notice of appeal to the Court of Appeals.
The Court of Appeals, Fifth Division, in a Decision dated February 7, 2020, reversed the RTC and denied Arlo’s application, concluding Arlo failed to prove (1) that the lots are alienable and disposable because it did not present a certified true copy of the DENR’s original land classification, and (2) possession by Arlo or its predecessors-in-interest in the manner and period required. Arlo’s motion for reconsideration was denied on November 20, 2020. Arlo then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
While the petition was pending, Republic Act No. 11573 (effective September 1, 2021) amended portions of Presidential Decree No. 1529, notably changing the possession period requirement from “since June 12, 1945 or earlier” to at least twenty (20)...(Pro-only)
Issues:
- Did Arlo sufficiently prove entitlement to a decree of registration over Lot Nos. 7948 and 7947? ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)