G.R. No. 170181 - Hanjin Heavy Industries and Construction Co. Ltd. vs. Ibanez

Remman Enterprises, Inc. (the petitioner) filed an application for land registration on June 4, 1998, with the Regional Trial Court (RTC) of Pasig City, Branch 155, in LR Case No. N-11379.
The subject properties consist of three parcels of land located in Barangay Napindan, Taguig, Metro Manila, with areas of 27,477 sq m, 23,179 sq m, and 45,636 sq m respectively.
Each parcel was described as a conversion of an existing lot under the Property Registration Decree (PD 1529) or Commonwealth Act 141, as amended.

The petitioner, represented by its authorized agent Ronnie P. Inocencio, submitted documentary evidence during the initial hearing on May 4, 1999, intended to prove compliance with jurisdictional and substantive requirements for land registration.
Inocencio testified that the properties were purchased on August 28, 1989 from sellers Magdalena Samonte, Jaime Aldana, and Virgilio Navarro and were subsequently occupied and utilized for agriculture.
Witness testimony by Cenon Serquina supported the petitioner’s claim by asserting that he had served as caretaker of the properties since 1957 and that no other party had asserted any right over them.

On November 27, 2001, the RTC rendered a decision granting the petitioner's application for registration, declaring Remman Enterprises, Inc. as the absolute owner in fee simple of the three parcels.
The decree ordered the issuance of a corresponding registration decree upon finality of the decision.

The State, represented by the Office of the Solicitor General, opposed the registration application and appealed on both substantive and procedural grounds.
The grounds for the appeal included:

Insufficient establishment of the true identity of the subject properties due to inadequacies in the survey plans, technical descriptions, and the absence of the original tracing cloth plan approved by the Director of Lands.
Failure on the part of the petitioner to present a certification showing that the properties were declared alienable and disposable.
The petitioner’s inability to prove that it and its predecessors-in-interest possessed the properties under a bona fide claim of ownership for the statutory period, specifically since June 12, 1945 or earlier.

On May 23, 2008, the CA reversed the RTC decision, setting aside the registration order and dismissing the petitioner’s application.

Remman Enterprises, Inc. subsequently filed a petition for review on certiorari before the Supreme Court, seeking to assail the May 23, 2008 Decision and the subsequent Resolution dated June 22, 2009 of the CA.
The petitioner maintained that:

The identity of the subject properties was sufficiently established through the submitted survey plans, technical descriptions, and, allegedly, original tracing cloth plans.
The properties’ status as alienable and disposable was established through a certification issued by the Community Environment and Natural Resources Office (CENRO) of the Department of Environment and Natural Resources (DENR).
The possession requirements, including possession within the required time frame, were met.

The State contended that the evidentiary requirements for registration, particularly regarding property identity and alienability/disposability, were not met.

Whether the evidence submitted by the petitioner—including survey plans, technical descriptions, and purported tracing cloth plans—was sufficient to establish the true identity and boundaries of the subject properties.
Whether the petitioner adequately proved that the subject properties are alienable and disposable, in compliance with the statutory and administrative requirements, particularly through the proper certification and submission of the original classification approved by the DENR Secretary.
Whether the petitioner and its predecessors-in-interest established that they possessed the subject properties openly, continuously, exclusively, and under a bona fide claim of ownership since June 12, 1945 or earlier.
Whether the procedural and substantive defects alleged by the State regarding the petitioner’s application for registration were correctly identified, thereby justifying the reversal of the RTC’s decision by the CA.