G.R. No. 218345 - Republic vs. Estate of Santos

The case involves a Petition for Review on Certiorari seeking to reverse the May 22, 2015 Decision of the Court of Appeals (CA) which had affirmed the Metropolitan Trial Court’s (MeTC) granting of an application for land registration.
The subject matter is a land registration case for Lot No. 10839-C in Taguig City based on Section 14 of Presidential Decree (P.D.) No. 1529.
Respondent Estate of Virginia Santos, represented by its administrator Pacifico Santos, filed the application for registration, asserting continuous possession and occupancy of the land based on a bona fide claim of ownership for over thirty (30) years.

Letters of Administration and Oath of Office showing Pacifico Santos’s authority as administrator.
The Subdivision Plan (Csd-00-000352) of Lot No. 10839 with annotations indicating the survey was within L.C. Map No. 2623 and classified as alienable/disposable.
Technical Description of Lot No. 10839-C and a Certification in Lieu of Surveyor’s/Geodetic Engineer’s Certificate issued by the DENR.
A Tax Declaration (T.D. No. FL-013-01057) and an Extrajudicial Settlement of Estate by the sole heir of the late Alejandro Santos.

The respondent contended that Virginia Santos, as the sole heir of Alejandro Santos, had acquired and been in open, continuous, exclusive, and adverse possession over the subject land for more than thirty years.

On April 30, 2007, the Republic of the Philippines, represented by the Office of the Solicitor General (OSG), filed an Opposition to the application raising several grounds:

The Republic argued that neither Virginia nor her predecessors-in-interest had maintained the requisite open, continuous, exclusive, and notorious possession for not less than 30 years.
It disputed the evidentiary value of the tax declarations and related receipts, holding that they merely indicated a claim and did not prove ownership.
It also claimed that any claim of ownership based on a Spanish title or grant was no longer viable and that the subject land, being part of the public domain, was not eligible for private appropriation.

The Land Registration Authority (LRA) later provided a report affirming that the subject property did not overlap with any previously decreed properties and noted discrepancies regarding whether the land was covered by earlier surveys.

The MeTC initially issued a decision on August 31, 2011, denying the application for registration on the ground that respondent Estate failed to establish sufficient evidence of both possession and the alienable and disposable nature of the property.
A Motion for Reconsideration was filed by the respondent, which led the MeTC to grant it on February 24, 2012, permitting the presentation of additional evidence.
Relying on new testimonies, including those of Romualdo Flores and Felino Flores, the MeTC reversed its earlier decision and in its Amended Order dated April 5, 2013, declared the title of the Estate of Virginia Santos over Lot No. 10839-C and ordered its registration.
The Republic, dissatisfied with this outcome, elevated an appeal to the CA.

The CA, in its May 22, 2015 Decision, upheld the registration by affirming the MeTC’s amended order.
The CA’s ruling was heavily influenced by judicial notice of the cadastral survey used in the earlier Sta. Ana Victoria case, asserting that the certification on the survey plan sufficed to prove that the land was alienable and disposable as well as to establish possession.
The Republic challenged this reliance, questioning both the evidentiary basis for possession and the appropriateness of employing judicial notice from a different case.
The petition later raised three primary grounds against the CA’s decision, contending errors in judicial notice, discrepancies in land area, and insufficient evidence of possession dating as early as June 12, 1945, or earlier.

Whether the CA erred in taking judicial notice of a cadastral survey from a different case (Sta. Ana Victoria) to establish the alienable and disposable character of the subject land.
Whether the CA committed reversible error in affirming the registration application despite discrepancies in the total area of the parcel and the insufficiency of evidence regarding the open, continuous, exclusive, and notorious possession required under Section 14 of P.D. No. 1529.
Whether respondent Estate failed to meet the evidentiary requirements under Section 14(1) and Section 14(2) of P.D. No. 1529, including proving possession and occupancy since June 12, 1945, or earlier, and demonstrating an express conversion of public land to patrimonial status necessary for prescription.