Facts:

The case involves Samuel and Edgar Buyco as petitioners against the Republic of the Philippines as the respondent. The events leading to this case began on October 14, 1976, when the Buyco brothers, through their attorney-in-fact Rieven H. Buyco, filed an application for the registration of a large parcel of land, specifically Lot 1, Psu-127238, with an area of approximately 3,194,788 square meters located in the barrios of Canduyong, Anajao, and Ferrol in Odiongan, Romblon. The application was initially filed with the Court of First Instance of Romblon, which later became the Regional Trial Court (RTC). The Republic, through the Director of Lands, opposed the application, arguing that the Buycos were American citizens and thus disqualified from acquiring land in the Philippines, and that they had not established proprietary rights over the land.

On February 5, 1985, the RTC granted the application for land registration, but the Director of Lands appealed the decision. The ...

Facts:

Procedural History and Background

• The petitioners, Samuel and Edgar Buyco, filed a Petition for Review on Certiorari under Rule 45 assailing orders of the Court of Appeals (CA) in CA-G.R. CV No. 68708.
• The CA had reversed and set aside the Regional Trial Court’s (RTC) decision dated August 15, 2000, which had granted the petitioners’ application for land registration over a large parcel described as Lot 1, Psu-127238 (approximately 3,194,788 square meters).
• The case involves extensive factual and procedural history, beginning with the petitioners’ first registration attempt in 1976 and extending through various appeals and motions culminating in the CA’s decisions (including a denial of a motion for reconsideration on June 30, 2011) and later the present petition.

First Registration Application

• On October 14, 1976, brothers Edgardo H. Buyco and Samuel H. Buyco (through their attorney-in-fact) filed an application for registration of a parcel of land with the Court of First Instance of Romblon, Branch 82.
• The land was specifically described in great detail including its boundaries with neighboring properties and natural features, covering areas within barrios Canduyong, Anahao, and Ferrol in Romblon.
• The Republic of the Philippines, through the Director of Lands, opposed the application on several grounds:
• That the petitioners were American citizens and hence, under the Constitution, disqualified from acquiring lands in the Philippines.
• That the petitioners had allegedly established proprietary rights over the land prior to their naturalization as Americans.
• That the petitioners failed to overthrow the presumption that the land was public.
• The Land Registration Court rendered judgment on February 5, 1985, ordering the registration of the land in the petitioners’ names while annotating a mortgage interest of the Development Bank of the Philippines on the title.
• The Director of Lands appealed this decision, but the CA dismissed its appeal (docketed as CA-G.R. CV No. 05824).
• A petition under Rule 45 was then reviewed by the Supreme Court in G.R. No. 91189 (rendered on November 27, 1991), wherein the Supreme Court reversed the RTC decision and set aside the CA's ruling regarding the first application.

Second Registration Application

• On December 6, 1995, Edgar Buyco and Samuel Buyco filed a second application for registration covering the same parcel of land.
• Shortly thereafter, on February 23, 1996, the Republic (through its opposition) moved to dismiss the application on the grounds of:
• Res judicata, contending that the issue was already decided in the previous application.
• The argument that the petitioners did not acquire vested rights before becoming American citizens.
• The trial court, on May 29, 1996, denied the motion to dismiss by applying Section 37 of Act No. 496, noting that a dismissal “without prejudice” permitted a subsequent application if evidence supported the registration.
• Trial on the merits ensued, and on August 15, 2000, the RTC rendered judgment granting the registration application in favor of Samuel H. Buyco.
• The Republic, through the Office of the Solicitor General, filed a notice of appeal on September 4, 2000.
• Subsequent proceedings in the CA and orders (including requiring the parties to report any supervening events) eventually led the CA, in its Decision dated January 26, 2011, to reverse and set aside the RTC’s judgment, determining that res judicata was applicable.
• A motion for reconsideration by the petitioners was later denied by the CA in its Resolution dated June 30, 2011.

Evidentiary Records and Testimonies

• The petitioners sought to prove that the Subject Land was alienable and disposable through:
• Exhibit “DD”: A sketch plan and certification purporting to trace the land’s technical description and boundaries, allegedly indicating its alienable and disposable status.
• Exhibit “OO”: A one-page report by Romulae Gadaoni, Land Management Officer III of the DENR’s Community Environment and Natural Resources Office (CENRO), which included findings from an ocular inspection conducted in 1976 and again on July 3, 1998.
• Gadaoni’s testimony further described the physical features of the land (level and rolling terrain, presence of improvements and around 350 cows, fencing, and usage as cattle grazing).
• Despite these submissions, the proofs were found insufficient to conclusively establish that the land fell within the alienable and disposable zone.
• Legal precedents (e.g., In Re: Application for Land Registration Suprema T. Dumo v. Republic of the Philippines and Republic of the Philippines v. T.A.N. Properties, Inc.) require specific documentary evidence demonstrating:
• A copy of the original land classification approved by the DENR Secretary.
• A valid certificate of land classification status issued by a CENRO or PENRO.
• The evidence presented relied primarily on certifications and documents that did not meet these strict requirements.

Issue:

• Whether the CA erred in applying res judicata to a second land registration application even when the prior registration case (G.R. No. 91189) was already decided with finality.
• Whether the CA’s dismissal of the second registration application violated the petitioners’ due process rights by failing to acknowledge that the petitioners had removed or cured the registration obstacles identified in the previous decision.
• Whether the statutory exception under Act No. 496 (which allows a dismissal “without prejudice”) should permit a subsequent reapplication when the crucial evidentiary requirements regarding alienability and disposability remained unfulfilled.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)