G.R. No. 146527 - Republic vs. Manna Properties Inc.

On September 29, 1994, Manna Properties, Inc. (applicant-appellee) filed an application for the registration of title for two parcels of land located in Barangay Pagdaraoan, San Fernando, La Union (Lot No. 9515 and Lot No. 1006) measuring approximately 1,480 square meters.
The application involved the submission of pertinent documents—including a plan (Plan AS-013314-001434), technical descriptions, and postal money orders for publication—to the Land Registration Authority (LRA).

The initial hearing was initially set on February 16, 1995. However, the LRA noted deficiencies in the initial application (specifically, incomplete details of adjoining lot owners) and directed Manna Properties to file the complete names and addresses of owners of adjacent lots.
Manna Properties complied by filing the required information on December 14, 1994, leading to subsequent adjustments in the hearing schedule.

The hearing was first scheduled for April 13, 1995, but was reset to April 20, 1995, due to conflicts with Holy Thursday and in observance of LRC Circular No. 353.
A further request from the LRA, based on constraints with the National Printing Office (requiring materials 75 days in advance), resulted in another reset, moving the hearing to July 18, 1995.

The Notice of Initial Hearing, duly published in the Official Gazette (June 12, 1995 issue) and in a newspaper (The Ilocos Herald, July 12, 1995).
Technical documents such as the plan, technical descriptions, certificate in lieu of lost surveyor’s certificate, certificate of latest assessment, and other notices of publication.

Jose Tanyao, president of Manna Properties, testified regarding the acquisition of the subject property.
Manuel SobrepeAa, a predecessor-in-interest, provided his account emphasizing possession of the property.

The Regional Trial Court, Branch 26, San Fernando, La Union, rendered a decision on February 21, 1996, granting the application for title registration under Presidential Decree No. 1529 (Property Registration Decree).
The Office of the Solicitor General, representing the Republic of the Philippines (petitioner), promptly appealed the decision, leading to:

The Court of Appeals affirming the trial court’s decision on December 20, 2000, dismissing the relief sought by the petitioner.
A petition for review ultimately reaching the Supreme Court for consolidation and final resolution of the issues raised.

Whether Manna Properties failed to comply with the jurisdictional requirement under Presidential Decree No. 1529 by having the initial hearing set beyond the prescribed maximum period of 90 days.
Whether the process followed—particularly the publication of the notice in the Official Gazette and newspaper—satisfies the statutory requirement despite the delay caused by factors beyond the applicant’s control.

Whether Manna Properties sufficiently established open, continuous, and adverse possession of the property for the requisite period (since June 12, 1945) as mandated by Commonwealth Act No. 141 (Public Land Act).
Whether the evidentiary basis, including tax declarations, affidavits, and testimonies—especially the reliance on the substitute tax declaration (Exhibit Q-16) and Manuel SobrepeAa’s testimony—was adequate to satisfy this legal requirement.