Title
Buyco vs. Republic
Case
G.R. No. 197733
Decision Date
Aug 29, 2018
Brothers Buyco, American citizens, twice sought land registration in the Philippines but failed to prove the land was alienable and disposable; SC upheld res judicata and dismissed their application.
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Case Digest (G.R. No. 197733)

Facts:

Initial Application for Land Registration (1976):
On October 14, 1976, brothers Samuel and Edgar Buyco, through their attorney-in-fact, filed an application for land registration over a large parcel of land described as Lot 1, Psu-127238, located in barrios Canduyong, Anajao, and Ferrol, Odiongan, Romblon, with an area of approximately 3,194,788 square meters. The Republic of the Philippines, through the Director of Lands, opposed the application.

First Judgment (1985):
On February 5, 1985, the Regional Trial Court (RTC) granted the Buycos’ application, ordering the registration of the land in their names. The Director of Lands appealed, arguing that the Buycos, being American citizens, were disqualified from acquiring land in the Philippines, and that the land was presumed to be public land.

First Supreme Court Ruling (1991):
On November 27, 1991, the Supreme Court in The Director of Lands v. Buyco (G.R. No. 91189) reversed the RTC decision, holding that the Buycos failed to prove the land was alienable and disposable.

Second Application for Land Registration (1995):
On December 6, 1995, the Buycos filed a second application for registration of the same land. The Republic opposed, arguing res judicata and the Buycos’ lack of vested rights before acquiring American citizenship. The RTC denied the Republic’s motion to dismiss, reasoning that the first dismissal was without prejudice.

Second RTC Judgment (2000):
On August 15, 2000, the RTC again granted the Buycos’ application. The Republic appealed to the Court of Appeals (CA).

CA Decision (2011):
On January 26, 2011, the CA reversed the RTC decision, holding that res judicata applied and the first Supreme Court ruling was final. The Buycos’ motion for reconsideration was denied.

Issue:

  1. Whether the CA erred in not applying Henson v. Director of Lands, which held that a dismissal of a land registration application is not prejudicial unless explicitly adjudicated as government land.
  2. Whether the CA violated the Buycos’ right to due process by refusing to recognize that they had removed or cured the obstacles to registration mentioned in G.R. No. 91189.

Ruling:

The Supreme Court denied the Buycos’ petition. The Court held that the Buycos failed to adduce sufficient evidence to prove that the land was alienable and disposable, as required under Republic v. T.A.N. Properties, Inc. and Republic v. Lualhati. The CENRO certification presented by the Buycos was insufficient to establish the land’s alienable and disposable status. Consequently, their second application for registration must fail.

The Court affirmed the CA’s decision, reversing the RTC judgment and dismissing the Buycos’ application without prejudice.

Ratio:

  1. Alienable and Disposable Land: To prove that land is alienable and disposable, two documents are required: (1) a copy of the original classification approved by the DENR Secretary, certified as a true copy by the legal custodian, and (2) a certificate of land classification status issued by the CENRO or PENRO. A mere CENRO certification is insufficient.
  2. Res Judicata: The CA correctly applied res judicata, as the first Supreme Court ruling in Director of Lands v. Buyco had become final and binding.
  3. Due Process: The Buycos’ argument that they had cured the obstacles to registration was unsubstantiated, as they failed to provide the necessary evidence to prove the land’s alienable and disposable status.


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