Case Digest (G.R. No. 203560)
Facts:
Republic of the Philippines v. Apostolita San Mateo, Brigida Tapang, Rosita Accion, and Celso Mercado, G.R. No. 203560, November 10, 2014, Supreme Court Third Division, Velasco Jr., J., writing for the Court. Before the Court was a Petition for Review on Certiorari seeking reversal of the Court of Appeals' Decision dated September 14, 2012 in CA-G.R. CV No. 96390, which had affirmed the Regional Trial Court's November 3, 2010 decision ordering registration of the subject lot in the respondents' names.
Petitioners are the Republic of the Philippines, represented by the Office of the Solicitor General; respondents are Apostolita San Mateo, Brigida Tapang, Rosita Accion, and Celso Mercado (the applicants for registration). The respondents filed a Petition for Registration of Title on January 27, 1999 in the RTC of Pasig City (Branch 127) over a parcel described as Lot 3226, MCadm 590-D (originally 12,896 sq. m., later adjusted to 12,776 sq. m.) located in Ibayo, Napindan, Taguig City, claiming descent and long possession from their grandfather, Leocadio Landrito, supported principally by tax declarations (TDs), an extra-judicial settlement and survey plans.
The petition was noticed and published; government agencies (Office of the Solicitor General, City Prosecutor, DENR-South CENRO, Land Registration Authority, DENR central offices, and Land Management Bureau) and adjacent owners were notified. Oppositions were filed by Globe Steel Corporation (GSC), New Donavel Compound Neighborhood Association, Inc. (NDCNAI), and the Laguna Lake Development Authority (LLDA), asserting competing possession, filling activities by informal settlers, and that the lot lay below reglementary lake elevation and therefore formed part of inalienable public land. On July 25, 2008, the LRA filed a report and adjusted the area to 12,776 sq. m.
On November 3, 2010 the RTC (Judge Nicanor A. Manalo Jr., penned) granted the registration petition, finding respondents had open, continuous, exclusive and notorious possession since 1948 (tax declarations as good indicia of possession) and that the lot was alienable and disposable based on a May 29, 2000 DENR‑South CENRO report and an October 2, 2000 LLDA certification stating elevations above 12.50 meters. The RTC ordered registration after payment of taxes and fees.
The Republic appealed to the Court of Appeals, raising lack of jurisdictional notice because not all adjoining owners were named in the notice, insufficiency of proof of possession over the entire area, and that the lot is part of the public domain and inalienable. In its September 14, 2012 Decision in CA-G.R. CV No. 96390, the CA affirmed t...(Pro-only)
Issues:
- Did the trial court properly acquire jurisdiction over the petition for registration of title?
- Did the respondents prove possession of the subject property for the length of time required by law?
- Did respondents prove that the subject property is alienable and dis...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)