Case Digest (G.R. No. 217210)
Facts:
- The case involves the Republic of the Philippines (petitioner) against Capital Resources Corporation (CRC), Romeo Roxas, and the Register of Deeds of La Union (respondents).
- The dispute concerns a parcel of land in Barangay Pugo, Bauang, La Union, covered by Transfer Certificate of Title (TCT) No. T-23343.
- The land was initially granted to Vitaliano Dumuk via a Homestead Patent on July 26, 1924, leading to Original Certificate of Title (OCT) No. 137.
- OCT No. 137 was later cancelled and replaced by TCT No. T-6603 in the names of spouses Cecilio and Laura Milo.
- CRC and Roxas acquired the property from the Milos, resulting in TCT No. T-23343 issued on December 16, 1982.
- The property was subdivided into several blocks, including Block 35 (designated as a "salvage zone") and Block 36 (overlapping with the China Sea).
- A subdivision plan was approved in 1988 but cancelled by the Department of Environment and Natural Resources (DENR) in 2005.
- A 1987 cadastral survey indicated Blocks 35 and 36 were part of foreshore land and seabed.
- In 2003, a foreshore lease application by Alberto Hidalgo prompted protests from CRC and Roxas regarding TCT No. T-23343's validity.
- DENR investigations concluded the land had eroded due to sea waters, recommending reversion of Blocks 35 and 36 to the State.
- The Republic, through the Office of the Solicitor General, filed a complaint for cancellation of TCT No. T-23343 and reversion of the land to public domain.
- The Regional Trial Court (RTC) ruled in favor of the Republic, declaring Blocks 35 and 36 as foreshore lands and ordering their reversion.
- The Court of Appeals affirmed this decision, leading to the Republic's current appeal.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition for lack of merit.
- The Court affirmed the Court of Appeals' decision, which upheld the RTC's ruling that Blocks 35 and 36 ...(Unlock)
Ratio:
- The Court emphasized the principle of estoppel, stating that issues not timely raised in lower court proceedings cannot be considered on appeal.
- The Republic did not include contested issues in its original complaint and pre-trial brief, waiving its right to raise them later.
- The allegations in the complaint were limited to the status of Blocks 35 and 36 as foreshore lands; new issues in a motion for reconsideration were not part of the original pl...continue reading
Case Digest (G.R. No. 217210)
Facts:
The case involves the Republic of the Philippines as the petitioner against Capital Resources Corporation (CRC), Romeo Roxas, and the Register of Deeds of the Province of La Union as respondents. The dispute centers on a parcel of land located in Barangay Pugo, Bauang, La Union, which is covered by Transfer Certificate of Title (TCT) No. T-23343. The land was originally granted to Vitaliano Dumuk through a Homestead Patent on July 26, 1924, leading to the issuance of Original Certificate of Title (OCT) No. 137. This title was later cancelled and replaced by TCT No. T-6603 in the names of spouses Cecilio and Laura Milo. Subsequently, CRC and Roxas acquired the property from the Milos, resulting in the issuance of TCT No. T-23343 on December 16, 1982.
The property was subdivided into several blocks, including Block 35 and Block 36, with Block 35 designated as a "salvage zone" and Block 36 overlapping with the China Sea. In 1988, the subdivision plan was approved but was later cancelled by the Department of Environment and Natural Resources (DENR) in 2005. A cadastral survey in 1987 indicated that Blocks 35 and 36 were part of foreshore land and seabed. In 2003, a foreshore lease application was filed by Alberto Hidalgo, which led to protests from CRC and Roxas regarding the validity of TCT No. T-23343.
The DENR conducted investigations and concluded that the land had been eroded by sea waters, recommending the reversion of Blocks 35...