Case Digest (G.R. No. 175315)
Facts:
The case revolves around a petition for review on certiorari filed by the Republic of the Philippines (petitioner) against Moldex Realty, Inc. (respondent), concerning the application for registration of land titles for Lot Nos. 9715-B and 9715-C located in Alulod, Indang, Cavite. The application was initially filed on January 25, 2000, by Luis Erce, Rosa Cinense, and Maria Clara Erce Landicho, covering three parcels of land, Lot Nos. 9715-A (40,565 square meters), 9715-B (20,000 square meters), and 9715-C (20,000 square meters), aggregating a total of 80,565 square meters. Subsequently, the applicants sold Lot Nos. 9715-B and 9715-C to Moldex Realty, Inc., which then substituted the original applicants in the ongoing registration case, while Lot No. 9715-A was dropped from the application.
To support its claim of ownership, Moldex Realty, Inc. provided testimonies from Engineer John Arvin Manaloto, who asserted that the company purchased the land from the heirs of Ana Erce an
Case Digest (G.R. No. 175315)
Facts:
- Background of the Case
- This petition for review on certiorari was filed by the Republic of the Philippines challenging prior decisions of lower courts.
- The controversy involved the registration of title to two parcels of land, specifically Lot No. 9715-B and Lot No. 9715-C, located in Alulod, Indang, Cavite.
- Application for Registration and Land Transactions
- On January 25, 2000, Luis Erce, Rosa Cinense, and Maria Clara Erce Landicho originally applied for the registration of three parcels of land—Lot Nos. 9715-A (40,565 square meters), 9715-B (20,000 square meters), and 9715-C (20,000 square meters)—amounting to a total of 80,565 square meters.
- Subsequently, the applicants sold Lot Nos. 9715-B and 9715-C (totaling 40,000 square meters) to Moldex Realty, Inc. and were substituted by Moldex Realty, Inc. in the pending registration application, while Lot No. 9715-A was dropped from the proceedings.
- Evidence Presented and Testimonies
- Engineer John Arvin Manaloto, Assistant Manager of Moldex Realty, Inc.’s Technical Services Department, testified that:
- Moldex Realty, Inc. acquired the properties from the heirs of Ana Erce and Pedro Erce through two separate deeds of sale executed in 1997.
- The technical descriptions and the subdivision plan for the properties were duly approved by the Bureau of Lands.
- Tax declarations from both the Municipal Assessor of Indang and the Provincial Assessor of Trece Martires City revealed a chain of title indicating various owners from 1948 to 2001, culminating with Moldex Realty, Inc.
- Certification was obtained from the Forest Management Sector of the Community Environment and Natural Resources Office of Trece Martires City, declaring the properties as alienable and disposable public domain land as of March 15, 1982.
- Pio Atis, a 77-year-old farmer and long-time resident of Alulod, provided testimony that:
- He personally knew the property owners prior to the acquisition by Moldex Realty, Inc.
- His extensive familiarity with the area and experience as a tenant as well as a neighboring landowner affirmed that the Erce family possessed the properties before the war.
- Decisions Rendered by the Lower Courts
- The Regional Trial Court of Naic, Cavite rendered its decision on February 19, 2002, granting the registration of Lot Nos. 9715-B and 9715-C in favor of Moldex Realty, Inc.
- The Court of Appeals, in its January 6, 2006 decision, affirmed the RTC’s ruling and relied on the precedent set in Republic v. Naguit, emphasizing that an application for registration meets the alienable and disposable requirement if the land was classified as such at the time of application.
- Appeal by the Office of the Solicitor General
- The Solicitor General, representing the Republic, appealed the RTC’s decision contending that:
- Moldex Realty, Inc. failed to demonstrate open, continuous, exclusive, and notorious possession of the properties for the statutory period either from June 12, 1945, or for at least 30 years.
- The possession by Moldex Realty, Inc.’s predecessors-in-interest could not invoke adverse possession since the properties were only declared alienable and disposable in 1982.
- The appeal also questioned whether the Court of Appeals erred in relying on Republic v. Naguit instead of the decision in Republic v. Herbieto in assessing the possession requirements.
- Subsequent Developments and Motions
- On March 14, 2012, Moldex Realty, Inc. filed a Manifestation and Motion withdrawing its application for registration, asserting that despite favorable decisions by the RTC and CA, it chose to withdraw its claim.
- Petitioner filed a Comment in response to the withdrawal, while Moldex Realty, Inc. maintained that the favorable rulings should not only lead to dismissal of the petition but should reverse and set aside the lower court decisions.
- The withdrawal raised the issue of mootness and academic character of the case, as well as inquiries into the application of the relevant jurisprudence.
Issues:
- Whether the withdrawal of the land registration application by Moldex Realty, Inc. rendered the case moot and academic.
- Whether Moldex Realty, Inc. or its predecessors-in-interest sufficiently proved the requisite open, continuous, exclusive, and notorious possession of the property for the statutory period (from June 12, 1945 or for at least 30 years) needed for registration.
- Whether the Court of Appeals erred in its decision by relying on Republic v. Naguit instead of Republic v. Herbieto when assessing the requirements for possession and the classification of the land as alienable and disposable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)