G.R. No. 108926 - Republic vs. Court of Appeals

The petitioner (Republic of the Philippines) sought review and setting aside of the Court of Appeals’ decision dated February 8, 1993, which had affirmed the Regional Trial Court of Makati’s ruling confirming respondent Democrito O. Plaza’s title over a specific parcel of land.
The dispute originated from a petition filed on November 14, 1986 (amended on July 17, 1987) by petitioner-appellee for registration and confirmation of title, which was later opposed by the Republic and other private respondents.
Subsequent filings included memoranda by both parties and evidentiary presentations during various stages of the litigation, culminating in the appellate decision reviewed by the Supreme Court.

The property in dispute, encompassing 45,295 square meters in Liwanag, Talon (formerly Pamplona), Las Pinas, originally belonged to Santos de la Cruz as evidenced by early tax declarations dated 1913, 1917, and 1921.
Ownership passed successively through several individuals including Pedro Cristobal, Regino Gervacio, Diego Calugdan, and Gil Alhambra, with each acquisition supported by corresponding tax declarations from the years 1923, 1927, 1934, and 1960.
After Gil Alhambra’s death, his heirs partitioned the property, eventually transferring it via a “Deed of Sale With Mortgage” on July 5, 1966, to petitioner-appellee for P231,340.00, the transaction secured by a mortgage and later released on August 1, 1968.

Petitioner-appellee took possession of the property following the sale, consistently paying property taxes from 1966 up to 1986, and re-declaring the property in his name (as reflected in the 1985 tax declarations).
The petitioner-appellee claimed that he and his predecessors had been in open, continuous, exclusive, and notorious possession of the land since before or since June 12, 1945, based on documentary evidence and long-standing administrative records.
Improvements on the property were made, including its temporary conversion into a ricefield, substantiating the claim of effective cultivation and utilization even though permanent structures were not established.

The Republic of the Philippines and several private oppositors (including the Heirs of Santos de la Cruz, Kadakilaan Estate, Heirs of Hermogenes Rodriguez, and an intervening settlers association) contested the petitioner-appellee’s claim by challenging the sufficiency of proof regarding continuous possession and rightful title.
Oppositors argued that mere tax declarations and payments, which they maintained were of "recent vintage," did not suffice to evidence bona fide acquisition of ownership, and that the property, being part of the public domain, was not subject to private appropriation.
Witness testimony regarding possession was conflicting, with residents and caretakers testifying about their own limited connection to the property, while the petitioner-appellee’s documents and records set out an established chain of possession.

On January 3, 1991, Presidential Proclamation No. 679 was issued, withdrawing the property from sale or settlement and reserving it for the Slum Improvement and Resettlement (SIR) program under the National Housing Authority.
The Court of Appeals noted that the proclamation did not affect the registration of title for an owner who could prove a right to the property, as the reservation was subject to existing private rights.
An ocular inspection ordered by the lower court and reported by a court-appointed commissioner further contributed to establishing the factual background of the case.

Documented evidence included the deed of sale, tax declarations, tax payment receipts, and witness testimonies showing continuous possession by petitioner-appellee and his predecessors for over 30 years from June 12, 1945.
The trial court, followed by the Court of Appeals, found that such evidence established possession in the concept of ownership under relevant laws and existing jurisprudence.
The appellate decision underscored that registration merely serves as evidence of title and does not in itself vest ownership, a point that was central to the Court’s final analysis.

Whether petitioner-appellee proved by convincing evidence that he and his predecessors were in open, continuous, exclusive, and notorious possession of the property since at least June 12, 1945.
Whether tax declarations, tax payment receipts, the deed of sale, and related documents adequately established actual occupation and a bona fide claim of ownership.

Whether the issuance of Presidential Proclamation No. 679, which withdrew the property from sale and reserved it for SIR, adversely affected the registration of title or the private rights of the petitioner-appellee.
Whether the reclamation of private rights could override the statutory scheme allowing registration based on the evidence of possession.

Whether the conversion of the land into a ricefield and other minor improvements sufficed to demonstrate actual possession and an owner’s relationship to the property.
How conflicting testimonies regarding the presence and activities on the property impacted the overall claim of uninterrupted possession.

Whether the series of tax declarations and tax payment records could be regarded as strong indicia of ownership, thereby meeting the legal requirements under the Torrens system.
The role of these documents in corroborating the claim that the petitioner-appellee had long-standing possession and a bona fide claim to the property.

Whether the Court of Appeals properly applied its standard of review with respect to findings of fact, particularly given the doctrine of finality in appellate determinations.
Whether any aberrations in the procedural handling of oppositions and default settings invalidated the ultimate ruling on the registration of title.