Case Digest (G.R. No. 217336) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In July 1991, Spouses Ildefonso Alejandre and Zenaida Ferrer Alejandre filed before the Regional Trial Court (RTC) of Bangued, Abra (Branch 2) an application for registration of Lot No. 6487, Cad. 536, Plan Ap-CAR-000007, covering 256 square meters in Barrio Poblacion, Bangued, Abra, under Presidential Decree No. 1529. They alleged ownership by virtue of a Deed of Absolute Sale dated June 20, 1990, from Angustia Lizardo Taleon, and claimed they occupied the land openly, continuously, exclusively, and notoriously. The Office of the Solicitor General entered appearance for the Republic. The Land Registration Authority (LRA) initially reported discrepancies in the technical plan, prompting several rounds of verification and corrected surveys from 1991 to 1998, after which the area was adjusted to 262 sqm. On March 31, 2006, the RTC granted the registration; it issued an Amended Decision on June 12, 2008. The Republic appealed to the Court of Appeals (CA), which on February 27, 2015... Case Digest (G.R. No. 217336) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Application and Allegations
- On July 18, 1991, Spouses Ildefonso and Zenaida Alejandre filed an application under P.D. No. 1529 to register Lot 6487, Cad. 536, Ap-CAR-000007, with an area of 256 sq m in Barrio Poblacion, Bangued, Abra.
- They claimed ownership by virtue of a Deed of Absolute Sale executed June 20, 1990 by Angustia Lizardo Taleon and alleged open, continuous, exclusive, and notorious occupation.
- Regional Trial Court Proceedings
- The Office of the Solicitor General appeared (Sept. 16, 1991); the LRA reported discrepancies in the plan (Nov. 12, 1991). The RTC ordered default (Jan. 30, 1992) and allowed submission of corrected plans and evidence through 1993.
- After several technical corrections and hearings, the Republic filed opposition (June 1, 2000) on grounds that:
- Applicants did not satisfy Section 48(b), C.A. 141 (as amended by P.D. 1073) regarding possession since 1945;
- They failed to present genuine tax declarations and muniments of title;
- The land remained part of the public domain.
- The RTC granted the application (Decision March 31, 2006), and later issued an Amended Decision (June 12, 2008) increasing the area to 262 sq m.
- Court of Appeals and Supreme Court Petition
- The Republic appealed to the Court of Appeals (CA-G.R. CV No. 101259). On February 27, 2015, the CA denied the appeal, sustaining the Amended RTC Decision on the ground that the spouses acquired the land by sale (Sec. 14[4], P.D. 1529).
- The Republic filed a Rule 45 petition before the Supreme Court, arguing that the CA misappreciated facts and misapplied controlling laws and jurisprudence.
Issues:
- Sole Issue
- Whether the CA gravely misappreciated the facts and made findings inconsistent with the evidence on record.
- Whether the CA misapplied the applicable laws and jurisprudence in sustaining the land registration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)