G.R. No. 177790 - Republic vs. Vega

The Republic of the Philippines, through the Office of the Solicitor General (OSG), filed a Rule 45 Petition questioning the Court of Appeals decision affirming the trial court's grant of original registration of title on a land parcel in Los Baños, Laguna.
Respondents included Carlos R. Vega, Marcos R. Vega, Rogelio R. Vega, Lubin R. Vega, and heirs of Gloria R. Vega (respondents Vegas), along with respondents-intervenors Buhays (Romea G. Buhay-Ocampo et al.).

On May 26, 1995, respondents Vegas filed an application for registration of Lot No. 6191, Cadastre 450 of Los Baños, Laguna, comprising 6,902 square meters.
Respondents Vegas claimed ownership by inheritance from their mother, Maria Revilleza Vda. de Vega, who inherited it from her father, Lorenzo Revilleza. Siblings had died intestate without offspring.
The Republic opposed the application on June 21, 1995, alleging that the land or portions thereof were public domain lands not subject to private appropriation.

Respondents Vegas presented exhibits and witnesses proving possession, occupation, and ownership; notably, Rodolfo Gonzales, Special Investigator of CENRO Los Baños, testified and submitted an inspection report dated January 13, 1997, stating:

The land area was entirely within alienable and disposable zone under Project No. 15, L.C. Map No. 582 certified on December 31, 1925.
No public land application was filed for the land, and it was residential/commercial.

Respondents-intervenors Buhays moved to intervene claiming ownership over an 826-square meter portion sold by respondents Vegas’ mother to their predecessors. They submitted a subdivision plan (Csd-04-024336-D) indicating the land portion claimed.

Trial court granted the registration on November 18, 2003, directing issuance of the title to respondents Vegas and respondents-intervenors Buhays proportionally.
The Republic appealed, arguing failure to prove alienable and disposable character due to absence of a dated land classification from government officials, but the Court of Appeals affirmed the trial court’s ruling on April 30, 2007.
The Republic elevated the case through a Rule 45 Petition before the Supreme Court.

Respondents raised procedural defects including lack of pertinent records in the petition (e.g., the Appellee’s Brief) and raising factual rather than legal questions.
The Supreme Court found these procedural objections insufficient to dismiss the petition. The absence of certain documents is not fatal, and the petition raised questions of law (nature of the land’s classification), not purely factual issues.

Whether respondents Vegas sufficiently proved the subject land is alienable and disposable as required under the Property Registration Decree.
Whether the failure of respondents Vegas to submit both a CENRO certification and a certified true copy of the original land classification by the DENR Secretary invalidates their application for registration.
Whether the Court of Appeals committed reversible error in affirming the trial court’s grant of title registration.