Case Digest (G.R. No. 197389)
Facts:
Republic of the Philippines v. Manuel M. Caraig, G.R. No. 197389, October 12, 2020, Supreme Court Second Division, Hernando, J., writing for the Court.Petitioner is the Republic of the Philippines (represented by the Office of the Solicitor General, OSG); respondent is Manuel M. Caraig, who sought original registration of title to Lot No. 5525‑B. The Municipal Trial Court (MTC) of Sto. Tomas, Batangas (LRA MTC Case No. 2002‑028, LRA Record No. N‑75008) granted respondent’s application in a February 28, 2007 decision. The Court of Appeals (CA) affirmed in a January 31, 2011 decision and denied the OSG’s motion for reconsideration in a June 15, 2011 resolution. The OSG filed a petition for review on certiorari under Rule 45 to the Supreme Court.
On September 2, 2002 Manuel, through his attorney‑in‑fact Nelson N. Guevarra, filed for original registration of a 40,000 sq. m. portion of Lot No. 5525 (Lot No. 5525‑B) in Brgy. San Luis, Sto. Tomas, Batangas. He relied on a Deed of Absolute Sale dated September 25, 1989 from Reynaldo S. Navarro, a subdivision plan approved July 3, 2002, tax declarations, a technical description, and CENRO/DENR certifications dated February 11 and March 21, 2003 stating the parcel was within an alienable and disposable zone and not covered by any public land application or patent.
Only the OSG opposed the application, alleging the land was inalienable public domain and that Manuel and predecessors were not in continuous, exclusive, notorious possession since June 12, 1945; an Order of General Default was entered against the whole world except OSG. At trial Manuel presented several neighbors and acquaintances who testified that Evaristo Navarro (the predecessor) and later Reynaldo had possessed and cultivated Lot No. 5525 since the 1940s and that the sold portion (5525‑B) was subsequently occupied by Manuel, who built a house and planted crops. The MTC credited the evidence and adjudged registration in Manuel’s name. The CA affirmed, holding the attorney...(Subscriber-Only)
Issues:
- Does the petition present reviewable questions of law under Rule 45, or does it raise factual issues that preclude certiorari review?
- Are the CENRO certificates (February 11 and March 21, 2003) and the other documentary evidence sufficient to prove that Lot No. 5525‑B is alienable and disposable?
- Did Manuel prove, by competent evidence, open, continuous, exclusive and notorious possession under a bona fide claim of owner...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)