Case Digest (G.R. No. 172931)
Facts:
The case revolves around Republic of the Philippines, represented by the Department of Environment and Natural Resources (DENR), as the petitioner against the Regional Trial Court (RTC), Branch 18, Roxas City, and private respondents Rizal Recio, Teresita Recio, Paciencia Recio, and Harriet Villanueva Vda. de Recio, in G.R. No. 172931, decided on June 18, 2009. The dispute originates from a land registration case decided by the RTC on September 14, 1984. The RTC confirmed and registered title to Lot No. 900 of the Pilar Cadastre in favor of the Recios, which was recognized and formalized with Original Certificate of Title (OCT) No. 0-2107 issued on April 17, 1985.
However, in 1997, individuals living on Lot No. 900 filed a protest with the DENR, claiming that the land was part of a forest or timberland, thus not subject to private appropriation. Following inquiries conducted by Lorna L. Jomento, a Special Investigator at DENR, it was reported on January 19, 1998, that Lot No.
Case Digest (G.R. No. 172931)
Facts:
- RTC Decision and Registration of Title
- On September 14, 1984, the Regional Trial Court (RTC) of Roxas City, Branch 18, rendered a decision in Land Registration Case (LRC) No. N-785.
- a. The decision granted the Application for Registration of Title dated June 20, 1977, filed by Rizal Recio on behalf of himself, his brother Oscar Recio, and sisters Teresita and Paciencia Recio.
- b. The decree ordered the confirmation and registration of title to Lot No. 900 of the Pilar Cadastre, as described in the technical exhibit (Exhibit “E”) and the approved plan (Exhibit “X”).
- The decision became final and resulted in the issuance of Original Certificate of Title (OCT) No. 0-2107 on April 17, 1985, covering an 11,189-square-meter piece of land in the names of the Recio family.
- Protest and Investigation
- In 1997, several occupants of Lot No. 900 filed a protest before the Department of Environment and Natural Resources (DENR) in Roxas City.
- a. They contested the issuance of OCT No. 0-2107, arguing that the land was within forest lands or timberlands and should not be subject to private appropriation.
- Responding to the protest, Special Investigator Lorna L. Jomento of the Lands Management Department (LMD), DENR, conducted an ocular inspection and investigation.
- a. On January 19, 1998, she submitted a written report asserting that Lot No. 900 fell within forest lands under Project No. 20-A, as established by Forestry Administrative Order No. 4-1777 and depicted in Land Classification (LC) Map No. 3132.
- b. Jomento recommended that an action be instituted for the cancellation of OCT No. 0-2107.
- Petition for Annulment of RTC Judgment
- On September 9, 2002, the Republic of the Philippines, represented by the DENR and through the Office of the Solicitor General (OSG), filed a petition for annulment of judgment before the Court of Appeals.
- a. The petition sought to annul the RTC decision dated September 14, 1984, alleging that the RTC acted without jurisdiction by adjudicating title over land that was allegedly part of the public forest (thus inalienable and indisposable).
- b. The petition cited Section 14 of Presidential Decree No. 1529, which limits court adjudication to alienable and disposable lands, contending that the RTC exceeded its jurisdiction.
- Private Respondents’ Position and Subsequent Proceedings
- Private respondents, represented by members of the Recio family, argued that:
- a. The RTC had jurisdiction since, according to an approved plan (Plan LRC-SWO-14402) and Certification dated November 8, 1976, Lot No. 900 was shown to be within the alienable and disposable land block (LC Project No. 20) certified on September 28, 1960 via BFD Map LC-2401.
- b. The RTC’s decision, having become final and executory, was res judicata, rendering further litigation unnecessary.
- The Court of Appeals, following pre-trial and evidentiary proceedings including a pre-trial conference in 2003 and a Report and Recommendation in December 2005, dismissed the petition on May 25, 2006, for failure to adduce sufficient evidence proving that Lot No. 900 was forest land.
Issues:
- Jurisdictional Issue
- Whether the RTC acted without jurisdiction in allowing the registration of Lot No. 900 because the land was allegedly forest land (and therefore inalienable) and not subject to private appropriation.
- Evidentiary Burden
- Whether petitioner (the DENR/Republic) failed to discharge its burden of establishing, by the quantum of evidence required by law, that the subject parcel of land is inalienable and indisposable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)