Case Digest (G.R. No. 216691) Core Legal Reasoning Model
Facts:
In the case of Republic of the Philippines vs. Remman Enterprises, Inc., decided on February 19, 2014, the petitioner, the Republic of the Philippines, sought to annul the decision of the Court of Appeals (CA) affirming the Regional Trial Court (RTC) of Pasig City’s ruling that granted land registration to the respondent, Remman Enterprises, Inc., for two parcels of land located in Barangay Napindan, Taguig, Metro Manila. The parcels in question were identified as Lot Nos. 3068 and 3077, with areas of 29,945 square meters and 20,357 square meters, respectively. Remman Enterprises filed an application for judicial confirmation of title over these lands on December 3, 2001, claiming open, continuous, exclusive, and notorious possession since 1943, predating the June 12, 1945 cutoff date for prescriptive claims under Philippine law. The application was published in the Official Gazette and a newspaper, and a hearing was conducted on May 30, 2002, where only the Laguna Lake Develop
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Case Digest (G.R. No. 216691) Expanded Legal Reasoning Model
Facts:
On December 3, 2001, Remman Enterprises, Inc. (respondent) filed an application with the RTC for judicial confirmation of title over two parcels of land (Lot Nos. 3068 and 3077) located in Barangay Napindan, Taguig, Metro Manila. The RTC initially found the application sufficient and set an initial hearing, which was later reset to May 30, 2002. Notice of the hearing was published in the Official Gazette, a major newspaper (People’s Balita), posted on the subject lots, and at the Taguig City Hall bulletin board.At the initial hearing only the Laguna Lake Development Authority (LLDA) appeared, prompting an order of general default for parties other than LLDA; LLDA and, subsequently, the Republic of the Philippines, filed oppositions. LLDA argued that the lots are not part of the alienable and disposable lands, asserting that under Section 41(11) of R.A. No. 4850, lands below 12.50 m in elevation near Laguna de Bay form part of its bed. Meanwhile, the Republic contended that the respondent failed to prove possession dating back to June 12, 1945 or earlier.
During trial, the respondent presented testimonies from its corporate secretary, an authorized employee, a caretaker who claimed long association with the properties since 1957, and a geodetic engineer who conducted an actual survey showing elevations above 12.50 m. The respondent also produced documentary evidence such as a deed of sale from 1989, survey plans, technical descriptions, tax declarations (dated only for 2002), and DENR certifications stating that the properties are within the alienable and disposable lands. Conversely, LLDA’s witnesses, including two geodetic engineers, argued—based on a topographic map derived from a 1966 aerial survey—that the properties’ elevations (ranging from 11.33 m to 11.77 m) placed them below the reglementary level. The RTC ruled in favor of the respondent on May 16, 2007, finding that the evidence indicated that the properties were not part of the bed of Laguna Lake and that the respondent had proven possession dating back to 1943. The CA affirmed the RTC’s decision on November 10, 2011.
Issues:
The primary issue is whether the CA erred in affirming the RTC decision granting Remman Enterprises’ application for registration of title over the subject lands despite the contentions that:- The properties have not been conclusively proven to be alienable and disposable lands of the public domain due to insufficient evidence of official land classification by the DENR Secretary.
- The respondent failed to present well-nigh incontrovertible evidence of open, continuous, exclusive, and notorious possession dating back to or before June 12, 1945, as required under Section 14(1) of P.D. No. 1529.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)