Facts:

• The case is titled "Republic v. Spouses Benigno," with the Republic of the Philippines as the petitioner and spouses Dante and Lolita Benigno as the respondents.
• On November 2, 1995, the spouses applied for land registration with the Regional Trial Court (RTC) of Calamba, Laguna, under Presidential Decree No. 1529.
• They sought to register a 293-square meter lot in Barangay Batong Malake, Los Baños, Laguna, assigned as LRC Case No. 105-95-C to Branch 35 of the Calamba RTC.
• The RTC issued a decision on December 9, 2005, granting the application and confirming the title based on Tax Declaration No. 0284.
• The petitioner filed a notice of appeal on January 10, 2006, which was docketed as CA-G.R. CV No. 97995.
• Delays occurred due to the respondents' failure to submit required documents, leading to motions for dismissal and reconsideration.
• On October 9, 2012, the Court of Appeals (CA) dismissed the appeal for the petitioner's failure to file its appellant's brief on time.
• The petitioner’s motion for reconsideration was denied on January 22, 2013, prompting a petition for review on certiorari to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled in favor of the petitioner, reversing the decisions of the Court of Appeals dated October 9, 2012, and January 22, 2013.
• The Court set aside the December 9, 2005 de...(Unlock)

Ratio:

• The Supreme Court noted that while the Court of Appeals has the discretion to dismiss appeals for failure to file briefs, it must consider that illegal acts of government agents do not bind the State.
• The respondents failed to provide necessary documentary evidence to prove that the land was alienable and disposable public land, a legal requirement for registration.
• Applicants must demonstrate that the land is part of the disposable and alienable lands of the public domain and show open, continu...continue reading