Case Digest (G.R. No. 198585)
Facts:
- In June 2006, Metro Index Realty and Development Corporation (respondent) filed an application for judicial confirmation of title over three parcels of land in Barangay Alulod/Mataas na Lupa, Indang, Cavite, totaling 39,490 square meters.
- The application was filed with the Regional Trial Court (RTC) of Naic, Cavite, docketed as LRC Case No. NC-2005-0006.
- The respondent presented two witnesses: Enrico Dimayuga, the Project Documentation Officer, and Herminia Sicap-Fojas.
- Enrico testified that the respondent purchased the properties from Herminia, Melinda Sicap, and Hernando Sicap, and that the properties had been declared for tax purposes in the respondent's name since 2006.
- He also stated that the properties were classified as alienable and disposable by the Department of Environment and Natural Resources (DENR) and that there were no adverse claims from adjoining lot owners.
- Herminia testified that she and her siblings inherited the properties from their parents, who had been in possession since 1956, actively cultivating the land and paying taxes.
- The RTC granted the application, finding that the respondent and its predecessors had been in open, public, continuous, notorious, and adverse possession of the properties.
- The Court of Appeals (CA) upheld the RTC's decision, emphasizing the payment of taxes and the presence of some fruit-bearing trees as evidence of possession.
Issue:
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Ruling:
- The Supreme Court granted the petition, reversing and setting aside the CA's decision.
- The respondent's application for original registrat...(Unlock)
Ratio:
- The Supreme Court found that the respondent failed to prove compliance with the requirements of either Section 14 (1) or Section 14 (2) of P.D. No. 1529.
- The evidence showed that the possession and occupation of the properties by the respondent's predecessors-in-interest began in 1956, not on June 12, 1945, or earlier, as required by Section 14 (1).
- Additionally, the properties could not be acquired by prescription under Section 14 (2) because there was no official declaration that the properties were no longer intended for public service or the development of national wealth, which is necessary to convert public domain properties to patrimonial.
- The Cou...continue reading
Case Digest (G.R. No. 198585)
Facts:
In June 2006, Metro Index Realty and Development Corporation (respondent) filed an application for judicial confirmation of title over three parcels of land located in Barangay Alulod/Mataas na Lupa, Indang, Cavite, with a total area of 39,490 square meters. The application was filed with the Regional Trial Court (RTC) of Naic, Cavite, and was docketed as LRC Case No. NC-2005-0006. The respondent presented two witnesses: Enrico Dimayuga, the Project Documentation Officer, and Herminia Sicap-Fojas. Enrico testified that the respondent purchased the properties from Herminia, Melinda Sicap, and Hernando Sicap, and that the properties had been declared for tax purposes in the respondent's name since 2006. He also stated that the properties were classified as alienable and disposable by the Department of Environment and Natural Resources (DENR) and that there were no adverse claims from adjoining lot owners. Herminia testified that she and her siblings inherited the properties from their parents, who had been in possession since 1956, actively cultivating the land and paying taxes. The RTC granted the application, finding that the respondent and its predecessors had been in open, public, continuous, notorious, and adverse possession of the properties. The Court of Appeals (CA) upheld the RTC's decision, emphasizing the payment of tax...