Case Digest (G.R. No. 108998) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The Republic of the Philippines, as petitioner, sought to nullify the decision of the Court of Appeals, which had affirmed the Regional Trial Court of San Pablo City’s approval of spouses Mario B. Lapina and Flor de Vega’s application for registration of title over two parcels of land—Lots 347 and 348, Cad. s38-D, totaling 91.77 square meters in San Pablo City. On June 17, 1978, the spouses, then natural-born Filipino citizens, purchased these lots from Cristeta Dazo Belen, whose family had openly, continuously, exclusively, and notoriously occupied the property since 1937 under a bona fide claim of ownership. On February 5, 1987, having since been naturalized Canadian citizens, the spouses filed for confirmation of their title under the Torrens system. The Republic opposed, contending that the prohibition against alien acquisition of private lands barred their registration since they were foreign nationals at the time of application. Both trial and appellate courts ruled in fav Case Digest (G.R. No. 108998) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Transaction
- On June 17, 1978, spouses Mario B. Lapina and Flor de Vega (then Filipino citizens) purchased Lots 347 and 348, Cad. s38-D (91.77 sq m) in San Pablo City from Cristeta Dazo Belen.
- On February 5, 1987, now naturalized Canadian citizens, the spouses filed with the RTC an application for registration of title over those lots as private lands.
- Lower Court Proceedings
- The Republic of the Philippines opposed, invoking the Regalian doctrine and questioning respondents’ possession period and foreign nationality.
- RTC Branch XXXI granted the application, confirming respondents’ title and directing issuance of a decree of registration with an easement annotation.
- The Court of Appeals affirmed, holding (a) the spouses acquired ownership in 1978 while Filipino, (b) Torrens registration merely confirms, not confers, title, and (c) their predecessors-in-interest had possessed the land since at least 1937, satisfying PD 1529/CA 141.
- Petition for Review
- The Republic sought nullification before the Supreme Court, arguing the land remained public until registration, respondents lacked required possession since June 12, 1945, and foreign nationals cannot register private land without complying with BP 185.
Issues:
- Whether spouses Mario B. Lapina and Flor de Vega, now Canadian citizens but natural-born Filipinos at the time of purchase, may apply for Torrens registration of private land they acquired in 1978.
- Whether the possession by respondents and their predecessors-in-interest met the requirements of CA 141/PD 1529 to convert alienable public land into private property.
- Whether BP 185’s limitations and documentary requirements for former Filipino citizens turned foreigners apply to the judicial confirmation stage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)