Case Digest (G.R. No. 195636)
Facts:
Spouses Dante SJ. Manzana and Sonia R. Manzana v. Republic of the Philippines, G.R. No. 195636, November 06, 2023, Supreme Court Second Division, Kho, Jr., J., writing for the Court. Petitioners are spouses Dante and Sonia Manzana (applicants); respondent is the Republic of the Philippines, represented by the Office of the Solicitor General (OSG). The Municipal Trial Court (MTC) of Morong, Rizal sat as Land Registration Court below.On September 10, 2002, spouses Manzana filed an Application for original registration under P.D. No. 1529 (Property Registration Decree) for Lot 5653, Psc-16 (2,815 sq.m.) in Brgy. San Juan, Morong, Rizal, alleging acquisition by Deed of Sale from Caridad Bonifacio, continuous and peaceful possession in the concept of owner, and attaching a tax declaration and survey plan. The Republic, through the OSG, opposed, contending the parcel is public domain and that the applicants failed to prove open, continuous, exclusive and notorious possession since June 12, 1945 as required by Section 14(1) of P.D. No. 1529.
The Land Registration Authority (LRA) filed a report noting a discrepancy: the plan, when plotted in the municipal index sheet, was of a “doubtful position” vis-à-vis adjoining lots and thus LRA requested the DENR cadastral map for verification. The Manzanas presented three witnesses, including an LRA examiner, Engr. Ricardo Nilo, who at first testified that the lot appeared in a doubtful position and recommended waiting for DENR verification, but later testified that a DENR Reply (May 26, 2003) removed the doubtful-position remark and the lot could be registered. A CENRO (DENR) report certified the land as within the alienable and disposable zone per an old land classification map (Project No. 16, released March 11, 1927). Copies of the DENR cadastral map and certified computations, however, were not submitted to the MTC record.
On June 25, 2008, the MTC granted the application and declared title in favor of spouses Manzana, ordering the LRA to issue a decree of registration upon finality. The OSG appealed to the Court of Appeals (CA). In a Decision dated June 28, 2010, the CA reversed the MTC, holding the Manzanas failed to prove possession since June 12, 1945 as required by Section 14(1) P.D. No. 1529; it also found continuing doubt in the technical description because the LRA had requested DENR verification and t...(Subscriber-Only)
Issues:
- Was it proper for the OSG to directly appeal the MTC Decision to the Court of Appeals?
- Did the Court of Appeals err in reversing the MTC Decision and dismissing the Application for original registration under P.D. No. 1529 for failure to prove the possession elements in Section 14(1) or permissibly rely on Section 14(2), and for finding doubt in the technical description?
- Should R.A. No. 11573 (which amends Section 14 of P.D. No. 1529) apply to this pending case, and if so, is remand to the court of origin f...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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