Case Digest (G.R. No. 237714)
Facts:
On November 20, 2014, Science Park of the Philippines, Inc. (SPPI), represented by its Executive Vice-President and General Manager Richard Albert I. Osmond, filed an Application for Original Registration (LRC No. N-129) with the Municipal Circuit Trial Court of Malvar-Balete, Batangas (MCTC) over a 7,691-square-meter parcel known as Lot 5809, Psc-47, Malvar Cadastre, Barangay Luta Norte, Malvar, Batangas. SPPI alleged that the subject land formed part of the alienable and disposable public domain, that it and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since before June 12, 1945, that the land was unencumbered and unclaimed by others, and that SPPI acquired it from Cenen D. Torizo by a Deed of Absolute Sale dated October 17, 2013. To establish classification, SPPI offered a certificate dated February 26, 2016 from the DENR-CENRO, Batangas City, confirming the land’s inclusion in the alienabCase Digest (G.R. No. 237714)
Facts:
- Procedural Background
- On November 20, 2014, Science Park of the Philippines, Inc. (SPPI) filed with the Municipal Circuit Trial Court of Malvar-Balete, Batangas (MCTC) an application for original registration of Lot 5809, Psc-47, Malvar Cadastre, a 7,691-sqm parcel under PD 1529.
- The MCTC granted the application on August 10, 2016. The Court of Appeals (CA) affirmed on October 12, 2017 and denied reconsideration on February 9, 2018. SPPI then filed a petition for review on certiorari before the Supreme Court.
- SPPI’s Evidence on Title and Possession
- Alienability/Disposability
- Certification dated February 26, 2016 by DENR-CENRO Batangas confirming the land is alienable and disposable under DAO 97-37 and LC Map No. 3601.
- Certified photocopies of DAO 97-37 and LC Map No. 3601.
- Possession Since June 12, 1945 or Earlier
- Chain of title and possession: Gervacio Lat’s 1955 tax declaration; tenancy and cultivation; descent to Ambrocia Lat; sale to Spouses Linatoc (1968); extrajudicial settlement (1995) in favor of Ernesto Linatoc; sale to Cenen D. Torizo (2012); sale to SPPI (2013).
- Testimony of Nelia Linatoc-Cabalda claiming to have observed cultivation and use of the land since about 1943.
- Government’s Opposition
- Alleged Failure to Prove Alienability/Disposability
- DAO 97-37 was not properly authenticated by a DENR records custodian.
- Improper judicial notice of documents from another case.
- Alleged Failure to Prove Possession Pre-1945
- Earliest documentary evidence of possession only dates from 1955.
- No identification of predecessors-in-interest before Gervacio Lat.
Issues:
- Whether SPPI sufficiently proved that the subject land forms part of the alienable and disposable lands of the public domain at the time of filing.
- Whether SPPI and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945 or earlier.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)