Case Digest (G.R. No. 240764)
Facts:
Kawayan Hills Corporation v. The Honorable Court of Appeals, Justices Juan Enriquez, Jr., Apolinario Bruselas, Jr., Manuel Barrios, Amelita G. Tolentino, and the Republic of the Philippines, G.R. No. 203090, September 05, 2018, the Supreme Court Third Division, Leonen, J., writing for the Court.Petitioner Kawayan Hills Corporation (a domestic real estate corporation) sought judicial confirmation and registration of title to a 1,461-square-meter parcel identified as Cad. Lot No. 2512 in Barangay No. 22, Nagbacalan, Paoay, Ilocos Norte. Kawayan Hills alleged acquisition through a Deed of Adjudication with Sale dated December 27, 1995 from Servando Teofilo and Maria Dafun, successors-in-interest of Andres Dafun, who had declared the property for real property tax purposes since 1931 and whose family allegedly cultivated and harvested the land since World War II.
On August 7, 2001 Kawayan Hills filed its application for confirmation and registration in the Municipal Circuit Trial Court (MCTC) of Paoay‑Currimao (Land Registration Case No. N-4), submitting among others: tax declarations (ARP No. 96‑025‑02624), a Deed of Adjudication with Sale (1995), certificates from DENR/CENRO (including a CENRO Laoag report of Feb. 9, 2004 declaring the land alienable and disposable), DAR exemption, municipal treasurer certificates of tax payment/non‑delinquency, and a technical survey/plan. On September 4, 2001 the Republic of the Philippines, through the Office of the Solicitor General (OSG), filed an opposition arguing petitioner failed to satisfy Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree).
The MCTC, by Decision dated July 8, 2010, ruled for Kawayan Hills, finding that Andres and his successors had been in open, continuous, exclusive and notorious possession and occupation under a bona fide claim of ownership since at least 1942, and ordered registration in Kawayan Hills’ name. The OSG appealed to the Court of Appeals (CA). In a Decision dated January 11, 2012 the CA reversed the MCTC, holding Kawayan Hills failed to prove a bona fide claim of ownership dating to June 12, 1945 or earlier and relying on the rule that tax declarations are not conclusive evidence of ownership; it likewise found the alternative theory under Section 14(2) lacking because there was no express government manifestation converting the property into patrimonial (citing Article 422, Civil Code). Kawayan Hills’ Motion for Reconsideration and subsequent motions were denied in CA resolutions dated June 28, 2012, July 17, 2012 and August 15, 2012.
Kawayan Hills filed a Petition for Certiorari under Rule 65 on September 6, 2012 before the Supreme Court, alleging the CA acted with grave abuse of discr...(Pro-only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion amounting to lack or excess of jurisdiction in reversing the MCTC's confirmation of Kawayan Hills’ imperfect title?
- Is petitioner Kawayan Hills Corporation entitled to confirmation and registration of title to Lot No. 2512 under Section 14(1) of Presidential Decree No. 1529?
- If not under Section 14(1), could petitioner prevail under Section 14(2) by acquisitive prescription (i.e., was there an express government manifestation ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)