G.R. No. 175578 - Republic vs. Guinto-Aldana

The petitioner is the Republic of the Philippines, represented by the Office of the Solicitor General, challenging the actions of the respondents.
The respondents are Zenaida Guinto-Aldana—in her capacity as attorney-in-fact for Ma. Aurora Guinto-Comiso, Ma. Luisa Guinto-Dionisio, Alfredo Guinto, Jr., Pacita R. Guinto, Ernesto R. Guinto, Natividad R. Guinto, and Alberto R. Guinto—who jointly filed an application for original registration of title.
The case originated with the filing of an application at the Regional Trial Court (RTC) of Las PiAas City, Branch 199, in LRC Case No. 02-0036, for the registration of title over two pieces of land.
The RTC rendered a decision on July 10, 2003, denying the registration, which was subsequently reversed by the Court of Appeals on March 30, 2006, with a resolution on November 20, 2006.
The petitioner, in its petition under Rule 45 for review, contests the Court of Appeals’ reversal of the RTC decision.

The subject property consists of two lots identified as Lot No. 4 and Lot No. 5, located in Talango, Pamplona Uno, Las PiAas City.
The lots measure 1,509 square meters and 4,640 square meters, respectively, as detailed in Conversion Consolidation Subdivision Plan Ccs-007601-000040-D.
The respondents claim co-ownership based on succession from their predecessors Sergio Guinto and Lucia Rivera-Guinto.
The title or origin of the property traces back to a 1969 document titled “Kasulatan sa Paghahati ng Lupa na Labas sa Hukuman na may Pagpaparaya at Bilihan,” wherein previous owners acquired shares from others who had derived their rights from Romulado Guinto.

A blueprint copy of the survey plan (Plan Ccs-007601-000040-D).
Technical descriptions of each lot.
Certification from a geodetic engineer.
Tax declarations and payment receipts demonstrating regular real estate tax payments.

Respondents also referenced an earlier filing involving the original tracing cloth plan, previously forwarded to the Land Registration Authority (LRA) in connection with LRC Case No. LP-128.
During the hearing, Zenaida and other respondents provided testimonies regarding the long-held possession and historical ownership of the property.
Testimonies corroborated by adjoining lot owner Josefina Luna attested to the respondents’ claim and continuous possession, despite the absence of the original tracing cloth plan.

The property had been in her family’s possession since her early childhood.
Her parents, Sergio and Lucia, acquired the property and maintained it through successive generations.
Structural improvements such as the construction of an adobe fence (later reinforced) and the building of a house (later destroyed) further indicated continuous occupation.

Josefina Luna, an adjoining landowner, confirmed that the lots had long been recognized as belonging to Zenaida’s parents and mentioned that no third party had contested their possession.
Additional documentary evidence including tax declarations (dating as early as 1937) and tax payment receipts between 1977 and 2001 reinforced the claim of actual, open, continuous, peaceful, and exclusive possession.

Found that the respondents failed to submit the original tracing cloth plan, a requirement under Presidential Decree (P.D.) No. 1529, which is necessary to clearly identify the property.
Concluded that the evidence did not satisfy the criteria of adverse, continuous, open, public, and exclusive possession because the testimonies did not conclusively establish the nature of the possession of the respondents’ predecessors.
Therefore, the application for registration was denied.

The Court of Appeals’ Ruling (March 30, 2006 Decision and November 20, 2006 Resolution):

Reversed and set aside the RTC’s decision, affirming the application for registration.
Held that the blueprint copy together with the technical descriptions substantially complied with the requirements of Section 17 of P.D. No. 1529, and that the evidence of possession was sufficient.

Argued that submission of the original tracing cloth plan is mandatory under Section 17 of P.D. No. 1529 for determining the exact identity of the property.
Claimed that merely submitting a blueprint copy, which was allegedly illegible and lacking certification, does not satisfy the legal requirement.
Asserted that there was no clear and convincing evidence establishing the 30-year period of possession required under the law.
Asserted that respondents should have retrieved the original plan from the LRA.

Contended that the blueprint copy, together with the technical description, sufficiently identified the property.
Argued that there was no objection from the oppositor or the LRA to the use of the blueprint, implying its adequacy.
Reiterated that their continuous payment of real estate taxes and longstanding possession established their bona fide claim of ownership.

Whether the blueprint copy of the survey plan (Plan Ccs-007601-000040-D) and the accompanying technical descriptions are sufficient to comply with Section 17 of P.D. No. 1529 in lieu of the original tracing cloth plan.
Whether substantial compliance with the requirement (as opposed to strict submission of the original document) is acceptable under the law.

Whether the respondents have presented clear and convincing evidence demonstrating that they and their predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the property for at least 30 years.
Whether tax declarations and receipts, as evidence of real estate taxation, adequately prove a bona fide claim of ownership.

Whether the failure to retrieve and submit the original tracing cloth plan, which was in the custody of the LRA, by the respondents is fatal to their application.
Whether the absence of any objection from the oppositor or the LRA to the use of the blueprint copy renders the submission substantially compliant.