Case Digest (G.R. No. 64818)
Facts:
Republic of the Philippines v. Maria P. Lee and Intermediate Appellate Court, G.R. No. 64818, May 13, 1991, Supreme Court Third Division, Fernan, C.J., writing for the Court.On June 29, 1976, Maria P. Lee (applicant) filed with the Court of First Instance of Pangasinan an application under the Land Registration Law to register a parcel of land of some 6,843 square meters in Mangaldan, Pangasinan, in the names of her and her husband, Stephen Lee. The Director of Lands, representing the Republic of the Philippines, opposed the application, alleging that the land was part of the public domain and that neither the applicant nor her predecessors-in-interest had the requisite open, continuous, exclusive and notorious possession in concept of owner for the statutory period required for confirmation of title.
At trial the applicant introduced documentary evidence: Deeds of Absolute Sale (dated March 18, 1963 and July 30, 1963) showing acquisition from Sixto Espiritu and Laureana Mataban, a Deed of Sale showing original vendor spouses Urbano Diaz and Bernarda Vinluan, tax declarations (Exhibits K and K-1) and official receipts for taxes paid (Exhibits L and L-1). In a one-page sworn declaration given before the commissioner on December 22, 1976, the applicant testified that her vendors had purchased from the Diaz spouses, who had possessed the land "for more than 20 years," and that she and her husband had been in possession for about thirteen years and sought to tack their possession to that of their predecessors.
The Court of First Instance, relying on the Land Registration Law (Act No. 496, as amended by R.A. Nos. 1942 and 6236), rendered judgment on December 29, 1976 confirming and adjudicating the title in favor of the spouses Stephen and Maria P. Lee and directing issuance of the decree and title. The Intermediate Appellate Court affirmed the CFI's decision in toto on July 29, 1983 (decision penned by Associate Justice Porfirio V. Sison, concurred in by Justices including Abdulwahid A. Bidin).
The Republic filed the present petition for review in the Supreme Court, challenging the lower courts' acceptance of what it characterized as an insufficient, self-serving and uncorroborated statement of long possession by the Diaz spouses and arguing that the applicant failed to produce the "conclusive" evidence required under the Land Registration and Public Land statutes to overcome the presumption that the land is public domain. The petition urged that the lower courts erred in (a)...(Pro-only)
Issues:
- Is the bare sworn statement of the applicant that her predecessors-in-interest possessed the land for more than twenty years sufficient, standing alone, to constitute the "well-nigh incontrovertible" or "conclusive" evidence required for registration under the Land Registration Law and Section 48(b) of Commonwealth Act No. 141, as amended?
- Does the failure of the representing fiscal to cross-examine the applicant operate to shift the burden of proof to the oppositor or otherwi...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)