G.R. No. 201031 - Leonidas vs. Vargas

On February 2, 2002, Tomas R. Leonidas (petitioner) filed an application for land registration covering Lot 566 and Lot 1677, located in Concepcion, Iloilo.
Petitioner claimed that he inherited the subject lots from his parents, Ponciano Leonidas, Jr. and Asuncion Roxas de Leonidas, based on a May 17, 1937 Certificate of Sale issued by the Provincial Treasurer of Iloilo.
He asserted that his predecessors-in-interest had taken possession of the lots—allegedly exercising dominical rights notoriously, continuously, and exclusively since the 1930s—and that the subject lots had gradually come into his own possession after his father’s death in 1991.

Original Survey Plans with photographic copies and a Tracing Cloth Plan.
Technical Descriptions, the Certificate of Sale dated May 17, 1937, and various tax declarations (e.g., TD No. 722, TDs for the years 1976, 1994, and 2003).
Tax payment receipts and a statement of the assessed value as certified by the Provincial Treasurer of Iloilo.
A Certificate of Unavailability in lieu of the surveyor’s certificate and additional evidence such as subdivision plans, ocular inspection reports, and certifications from Land Management Inspectors (PeAaflorida).

The Republic of the Philippines, represented by the Office of the Solicitor General, opposed the application arguing:

Neither petitioner nor his predecessors-in-interest satisfied the requirement of open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier.
The documentary evidence was insufficient and inconsistent—particularly regarding the timing and continuity of possession as evidenced by recent tax declarations and gaps in the possession history.
The subject lots, being portions of the public domain, should not be appropriated privately.

Tancredo Vargas, who filed his own Opposition on March 11, 2003, contended that:

He is the legitimate son and compulsory heir of Tomas, having acquired possession of a portion of the subject lots (including parts of Lot 566 and Lot 1677) through adverse possession and subsequent actions.
His claim was supported by tax declarations (which bore adverse annotations in petitioner’s favor) and his personal visits and improvements on the disputed portions.

They are the heirs of the late Mansueto Sicad who allegedly purchased a portion of the subject lots.
Their contested portion was evidenced by a Deed of Definite Sale and prior registration under an Original Certificate of Title (OCT).

Registration of a portion of Lot 566 and Lot 1677 in favor of petitioner, and
The remaining portions (identified as disputed) in favor of Tancredo, to be segregated in accordance with municipal survey plans.

Setting aside the portion adjudicated in petitioner’s favor (i.e. registration over Lot 566 and Lot 1677 as his private property).
Affirming the award of the disputed portions to Tancredo.

In his subsequent petition, the petitioner argued that his possession was sufficient and that the CA erred in evaluating the evidence and applying the requisite legal standards.

Whether the petitioner and his predecessors-in-interest have proven, with clear, positive, and convincing evidence, that they exercised open, continuous, exclusive, and notorious possession and occupation of the subject lots since June 12, 1945, or earlier.

Whether Tancredo Vargas successfully established a superior claim over the disputed portions of the subject lots through his own evidence of possession and adverse tax declarations.
Whether the conflicting evidence between the petitioner’s submission and Tancredo’s oppositions was properly weighed by the lower courts.

Whether the petitioner’s application for confirmation and registration under the Property Registration Decree (PD 1529) and Commonwealth Act No. 141 was supported by evidence showing the land’s status as alienable and disposable lands of the public domain as well as compliant possession conditions.

Whether the Court of Appeals gravely abused its discretion in reversing parts of the RTC decision and denying the registration of the petitioner’s claimed title.