G.R. No. 119288 - Republic vs. Court of Appeals

The Republic of the Philippines, represented by the Director of Lands, filed a petition for review on certiorari seeking annulment of the Court of Appeals decision affirming the Regional Trial Court (RTC) of Palawan’s August 12, 1993 judgment.
The cadastral case involves Lot No. 5367 in Barangay Los Angeles, Magsaysay, Palawan (Cadastral Case No. 13, GLRO Record No. 1133), claimed by private respondent Josefa Gacot (now deceased).

Josefa Gacot filed her answer on June 7, 1971, asserting co-ownership with Ceferino Sabenacio; hearings were set on August 9 and 13, 1990, but the government presented no evidence.
Claimant’s evidence: deed of sale (April 22, 1955) from Cipriana Dantic-Llanera; continuous, public possession for over 30 years; improvements and tax declarations in her name; waiver by Sabenacio; payment of property taxes up to date.
On September 5, 1990, the RTC rendered judgment adjudicating Lot No. 5367 to Josefa Gacot-Dantic, subject to estate tax.

The Republic appealed to the Court of Appeals (CA) and moved (December 26, 1991) to remand proceedings so it could present a 1950 decision by Judge Lorenzo Garlitos declaring the lot government property.
On remand, and after repeated hearings, the government again failed to formally offer the 1950 order or present witnesses; the RTC affirmed its earlier judgment on August 12, 1993.
The CA, in a February 22, 1995 decision, affirmed the RTC in toto, holding that the government could not invoke Republic Act No. 2061 (setting a 1968 time bar for public land claims) without formally offering the 1950 order.

Whether the Court of Appeals erred in ruling that, because the Republic of the Philippines failed to formally offer the October 20, 1950 order of Judge Garlitos, it had no basis to invoke R.A. No. 2061 to challenge Josefa Gacot’s late filing and to question the RTC’s jurisdiction.