Case Digest (G.R. No. 179987) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Mario Malabanan vs. Republic of the Philippines, G.R. No. 179987, decided En Banc on April 29, 2009 under the 1987 Constitution, Mario Malabanan filed on February 20, 1998 with the Regional Trial Court (RTC) of Cavite‐Tagaytay City, Branch 18, an application under Sections 14(1) and 14(2) of Presidential Decree No. 1529 (Property Registration Decree) to register Lot 9864-A, Cad-452-D, Silang Cadastre, Silang, Cavite (71,324 sqm). He alleged he purchased the parcel from Eduardo Velazco and, through his predecessors, exercised open, continuous, exclusive and notorious possession for over 30 years. The RTC, after trial, issued judgment on December 3, 2002 in Malabanan’s favor, directing issuance of the registration decree. The Republic, via the Office of the Solicitor General, appealed to the Court of Appeals (CA), which on February 23, 2007 reversed and dismissed the application. The CA held under its reading of Section 14(1) of PD 1529—as interpreted in Republic v. He Case Digest (G.R. No. 179987) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Application and Subject Land
- On February 20, 1998, Mario Malabanan filed an original registration application for Lot 9864-A, Cad-452-D, Silang Cadastre (71,324 sqm) in Barangay Tibig, Silang, Cavite.
- He alleged purchase from Eduardo Velazco and open, continuous, exclusive, and notorious adverse possession under a bona fide claim of ownership for over 30 years.
- Trial Court Proceedings
- The application was raffled to RTC Cavite-Tagaytay (Branch 18). Malabanan and his witness Aristedes Velazco testified; the Republic (represented by the OSG) presented no controverting evidence.
- A CENRO-DENR certification (June 11, 2001) confirmed the land as alienable and disposable per Map No. 3013, FAO 4-1656 (March 15, 1982).
- On December 3, 2002, the RTC granted registration under Act 141, Act 496 and/or P.D. 1529, ordering issuance of the certificate of title.
- Court of Appeals and Appeal to the Supreme Court
- The Republic appealed, contending Malabanan failed to prove alienability at the start of possession and the requisite length and manner of possession under PRD Sec. 14(1).
- On February 23, 2007, the CA reversed the RTC, excluding possession before March 15, 1982 (classification date), relying on Republic v. Herbieto.
- Malabanan died; his heirs continued the petition, invoking Republic v. Naguit and arguing Herbieto’s interpretation of Sec. 14(1) was obiter dictum.
- En Banc Supreme Court Hearing
- The case was heard en banc on November 11, 2008.
- The Court framed principal issues on the scope and interplay of PRD Sec. 14(1) (possession-based registration) and Sec. 14(2) (prescription-based registration).
Issues:
- PRD Section 14(1) (Imperfect‐Title Registration)
- Must a land be classified as alienable and disposable as of June 12, 1945, or is classification at any time before filing sufficient?
- May possession prior to classification be counted in the 1945‐based reckoning?
- PRD Section 14(2) (Prescription‐Based Registration)
- Can lands classified as alienable and disposable be deemed private and thus acquired by prescription under the Civil Code?
- Does agricultural character or slope-based classification affect registrability under Sec. 14(2)?
- Relief Sought
- Are petitioners entitled to registration under PRD Sec. 14(1) or Sec. 14(2), or both?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)