Case Digest (G.R. No. 213860) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The Heirs of Mario Malabanan, represented by Sally A. Malabanan (petitioners), sought judicial confirmation and Torrens registration of a 71,324-sqm parcel (Lot 9864-A, Cad-452-D) in Barangay Tibig, Silang, Cavite, under Presidential Decree No. 1529 (Property Registration Decree) and Commonwealth Act No. 141 (Public Land Act). Originally acquired by petitioners’ predecessor, Mario Malabanan, from Eduardo Velazco, the land’s ownership was anchored on open, continuous, exclusive and notorious possession under a bona fide claim of ownership. To establish alienability, Malabanan presented a June 11, 2001 CENRO-DENR certificate declaring the site alienable and disposable since March 15, 1982. On December 3, 2002, the RTC of Tagaytay City granted registration. The Office of the Solicitor General appealed, and on February 23, 2007 the Court of Appeals reversed based on Republic v. Herbieto, excluding possession before classification. The Supreme Court denied certiorari on April 29, 200 Case Digest (G.R. No. 213860) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property and Ownership
- The subject is Lot 9864-A, Cad-452-D, Barangay Tibig, Silang, Cavite, area 71,324 sq m.
- Mario Malabanan purchased it from Eduardo Velazco; claimed it formed part of the public domain.
- Trial Court Proceedings
- Feb 20, 1998 – Malabanan filed application for registration under PD 1529 (Property Registration Decree) in RTC Tagaytay City, claiming imperfect title under Sections 14(1)/(2).
- Alleged open, continuous, exclusive, notorious possession under bona fide claim for over 30 years.
- Evidence at Trial
- CENRO-DENR certification (Jun 11, 2001) stating the land was classified alienable/disposable since Mar 15, 1982.
- Testimony regarding ancestral occupation by the Velazco family.
- Lower Court Rulings
- Dec 3, 2002 – RTC ruled for Malabanan; directed issuance of certificate upon finality.
- Feb 23, 2007 – CA reversed (citing Republic v. Herbieto), excluding possession before formal classification.
- Supreme Court Action
- Apr 29, 2009 – SC denied petition for review; held classification need only exist at application, possession must date from Jun 12, 1945.
- Both petitioners and the Republic filed motions for reconsideration, challenging the interpretation of Sections 14(1) and 14(2).
Issues:
- Section 14(1) (Imperfect Title)
- Can possession before formal classification as alienable/disposable count toward the statutory period?
- Must classification date back to Jun 12, 1945, or only exist at application time?
- Section 14(2) (Prescription)
- Can petitioners register via prescription (Art 1134 Civil Code) linked to Sec 14(2) when classification occurred in 1982?
- Does acquisition by prescription start running upon reclassification as alienable/disposable?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)