G.R. No. 6791 - People vs. Que Po Lay

On September 10, 2002, spouses Dante SJ. Manzana and Sonia R. Manzana filed an Application for original registration of a 2,815-square meter parcel of land designated as Lot 5653, Psc-16, Morong Cadastral, before the Municipal Trial Court (MTC) of Morong, Rizal, acting as a Land Registration Court.
The spouses alleged ownership based on acquisition from Caridad Bonifacio through a Deed of Sale and claimed peaceful, continuous, exclusive possession under the concept of ownership without any third-party claims.
The application was supported by tax declarations, testimony of witnesses, and other documents indicating no encumbrance or mortgages affected the land.

The Republic of the Philippines, through the Office of the Solicitor General (OSG), filed an Opposition claiming the spouses did not establish possession since June 12, 1945 or earlier, and that the parcel was public domain not subject to private appropriation.
The LRA noted discrepancies in the survey plan's plotting, describing the property as in a “doubtful position” relative to adjoining lots and requested further cadastral verification from the Department of Environment and Natural Resources (DENR).
DENR later issued a letter stating the property was not in a doubtful position concerning adjacent lots but no certified cadastral map or lot data computations were submitted to the MTC.

Testimony of Sonia Manzana to prove material allegations.
Jeriel B. Villanueva testified about peaceful possession by his mother, Caridad Bonifacio, and subsequent sale.
Engineer Ricardo R. Nilo of the LRA testified to examination of documents, the doubtful position of the property initially found, the request for DENR cadastral map, and later the correction of the doubtful position based on DENR's reply.

The MTC issued a Decision on June 25, 2008, ruling in favor of the Manzanas and declaring ownership of the property.
The OSG, on behalf of the Republic, appealed this decision to the Court of Appeals (CA).
The CA, in a Decision dated June 28, 2010, reversed the MTC ruling, emphasizing failure to prove possession since June 12, 1945, questioned the technical description, and doubted the reliability of DENR’s certification.
The CA denied the Manzanas’ motion for reconsideration in its Resolution dated September 14, 2010.

Spouses Manzana challenged the CA’s ruling, asserting compliance with possession requirements under PD No. 1529, and argued the technical description was not doubtful.
They also contended that the OSG's direct appeal to the CA was improper.

Whether the CA erred in reversing the MTC Decision granting application for original registration under PD No. 1529.
Whether the claimants proved open, continuous, exclusive, and notorious possession since June 12, 1945, or at least twenty years immediately preceding the application, as required by law.
Whether the technical description discrepancies and doubtful position of the land were properly resolved.
Whether the OSG properly appealed from the MTC directly to the CA.