Case Digest (G.R. No. 172931)
Facts:
The Republic of the Philippines, represented by the DENR (through the OSG), sought annulment of the RTC of Roxas City, Branch 18 decision in LRC Case No. N-785, which confirmed and ordered registration of Lot No. 900 in the names of private respondents Rizal Recio, Teresita L. Recio, Paciencia L. Recio, and the heir of Oscar L. Recio, Harriet Villanueva Vda. de Recio. The RTC decision, dated September 14, 1984, became final and was implemented by the issuance of OCT No. 0-2107 on April 17, 1985.
In 1997, occupants protested DENR’s issuance of OCT No. 0-2107, claiming the land was forest land. DENR’s Special Investigator reported that Lot No. 900 lay within forest lands under Project No. 20-A and recommended court action for cancellation. Despite this, the Court of Appeals dismissed the petition for annulment of judgment on May 25, 2006, holding that DENR failed to prove by sufficient evidence that the land was inalienable forest land.
Issues:
- Did the RTC act without jurisdiction in allowing registration of Lot No. 900, allegedly inalienable forest land?
- Did petitioner fail to discharge the burden of establishing the inalienable character of the land by the quantum of evidence required?
Ruling:
The Supreme Court denied the petition and affirmed the Court of Appeals.
On the first issue, the Court held that at the time of the 1977 application and the 1984 RTC decision, the land was classified as alienable public land based on the Bureau of Forest Development certification dated November 8, 1976, so the RTC had jurisdiction to adjudicate the application.
On the second issue, the Court agreed that petitioner did not sufficiently prove that Lot No. 900 was forest land, noting that the RTC and CA findings of fact were binding on review, and that petitioner’s evidence did not overcome the cited certification.
Ratio:
The Court reasoned that jurisdiction in land registration cases depends on the land’s classification at the time of the application and decision; here, the Recios’ application in 1977 and the RTC’s ruling in 1984 were based on a certification that the land was within an alienable and disposable block, thus negating the claim that the RTC disposed of inalienable forest land without jurisdiction.
As to proof, the Court reiterated that in an action to annul a judgment, the petitioner bears the burden to establish the nullity of the judgment by clear and convincing evidence. The Court found that the Court of Appeals’ factual conclusion—DENR failed to sufficiently prove the forest character of Lot No. 900—was supported by the record, and the Supreme Court would not reweigh evidence when factual findings were adopted by the appellate court.
Doctrine:
- A court’s jurisdiction in land registration matters is tied to whether the land is alienable and disposable at the time of the application and decision.
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