G.R. No. 125986 - Luxuria Homes, Inc., and/or Aida M. Posadas vs. Honorable Court of Appeals, James Builder Construction and/or Jaime T. Bravo

The municipality of Taytay, as applicant and appellant, brought this appeal from the judgment of the Court of First Instance of Rizal rendered in registration proceeding No. 674, G.L.R. record No. 30408.
The case originated from a dispute over the registration of a parcel of land spanning over 305 hectares within the municipality, which had earlier been the subject of a registration application by the parish of Taytay in 1905.
Both the municipality of Taytay and the Insular Government (represented by the Director of Lands) filed oppositions to the parish’s registration application.
The Court of Land Registration, after duly conducting the proceedings, denied the inscription of the land to the parish. This adverse decision was affirmed on appeal.

The municipality of Taytay presented extensive evidence to support its claim of ownership, which included:

Exhibits 1 to 12 showing a continuous record of possession and municipal control.
Ancient documents such as a Royal Decree dated September 20, 1656, which highlighted the town’s historical possession and privileges.
Contracts, receipts, and municipal resolutions that demonstrated the collection of rents and other administrative acts in relation to the Tapayan lands.

Discrepancies in the documented area of the land (with one document showing 34 hectares, 29 ares, and 32 centares versus the application’s 305 hectares, 49 ares, and 49 centares).
The position that the land in question was part of the public domain, originally held by the Crown and later becoming property under the control of the Insular Government.

It was noted that the municipality of Taytay had maintained possession of the land for approximately two to three hundred years, with the municipal income from the land being devoted to public purposes and immediate municipal needs.
The evidence and historical records included references to disputes in earlier times between the parish and the municipality regarding the right to collect rents, with testimonies confirming that the municipality at present continued to enjoy the income from the land.
Relevant documents, such as the writ of protection issued in 1656 by Sabiniano Manrique de Lara, confirmed that while the town’s officials and natives had been granted the right to use and protect the land’s resources, the title itself had not been transferred to the municipality as private property.

The Court of Land Registration, in previous proceedings (notably in registration proceeding G.L.R. record No. 11271), had already addressed the matter, finding that the land belonged to the public domain, maintained by the Government of the Philippine Islands.
The decision relied heavily on a series of past rulings, including earlier declarations in proceedings numbered 1510, 1299, and 1928, which maintained that lands within municipal boundaries that were not expressly granted to a municipality remained government property.
Precedents such as City of Manila vs. Insular Government (10 Phil., 327) and Municipality of Tacloban vs. Director of Lands (18 Phil., 201) were cited, establishing that mere long-term possession or usufruct does not equate to an ownership title.

Whether the trial court erred in holding that the decision in the case of No. 1369, as confirmed by the Supreme Court in G.R. No. 3663, had become the law of the case concerning the question of ownership of the disputed lands.
Whether the lower court was correct in not finding that the parcels of land fall under the category of “Bienes de propios y bienes patrimoniales” belonging to the municipality of Taytay.
Whether there exists a presumption of grant in favor of the municipality, given its continuous possession and use of the land for nearly three centuries, including the collection of rents for public purposes.
Whether it was appropriate to apply the doctrine from Municipality of Tacloban vs. Director of Lands to the present case, resulting in the conclusion that the land is part of the public domain under the control of the Insular Government.
Whether the registration of the disputed land in favor of the Government of the Philippine Islands and the denial of the municipality’s motion for a new trial constituted a manifest error.