Case Digest (G.R. No. 74170)
Facts:
Republic of the Philippines v. Intermediate Appellate Court, G.R. No. 74170, July 18, 1989, First Division, Narvasa, J., writing for the Court. The petition was filed by the Republic of the Philippines through the Solicitor General; the named respondent was Guillermo Gonzalves, although the Court noted Gonzalves had been improperly impleaded and the real party in interest was Chua Kim alias Uy Teng Be.The dispute concerns three parcels adjudicated in Land Registration Cases Nos. 405 and 14817 in the Court of First Instance (CFI) of Quezon Province: Lots 1 and 2, Plan Psu-57676 (Opposition No. 51), and Lot 549, Plan AP-7521/ Psu-54565 (Opposition No. 155). Those lots were originally adjudicated to the spouses Manosca and the spouses Marquez, respectively. On December 27 and 30, 1934, the adjudicatees conveyed the lots to Gregorio Reyes Uy Un, who later died in 1946. Gregorio’s adopted son, Chua Kim (alias Uy Teng Be), took possession thereafter in the concept of an owner.
The three parcels later figured in Civil Case No. C-385 in the CFI at Calauag, Quezon, where plaintiffs and defendants executed a compromise agreement that included Chua Kim as a “Third Party” (although he had not been formally impleaded). The compromise required Chua Kim to renounce claims over specified parcels and, in turn, the other parties agreed not to oppose the transfer of ownership to him by lawful means. The CFI approved that compromise by judgment dated July 29, 1970 (amended July 31, 1970).
On January 7, 1977, Chua Kim became a naturalized Filipino citizen. He then filed a petition for decree of confirmation and registration in Land Registration Case No. 405 (LRC Rec. No. 14817). The Court of First Instance promulgated an order on January 14, 1982 granting his petition and directing entry of confirmation decrees and issuance of certificates of title in his name. The Republic appealed to the Court of Appeals, which affirmed the CFI order in a decision promulgated March 25, 1986.
The Republic then brought the case to the Supreme Court on appeal by certiorari, challenging (1) the adequacy of the deeds and instruments allegedly proving conveyance to Chua Kim and (2) Chua Kim’s qualification to own privat...(Subscriber-Only)
Issues:
- Are the factual findings of the Court of First Instance and the Intermediate Appellate Court binding on the Supreme Court?
- Were the deeds and instruments presented by Chua Kim adequate to prove conveyance to him?
- Can a person who was an alien at the time of acquisition be adjudged owner after subsequent naturalization — i.e., did Chua Kim’s prior alien status invalidate the conveyance or did his natur...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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