G.R. No. 78657-60 - People vs. Escano, Jr.

On December 22, 1994, petitioner Josephine Wee filed an Application for Registration of Title over a 4,870-square meter parcel of land situated in Barangay Puting Kahoy, Silang, Cavite, designated as Lot No. 8349 (Cadastral Lot No. 452-D).
Petitioner claimed ownership in fee simple, basing her title on a Deed of Absolute Sale dated February 1, 1993, executed by Julian Gonzales in her favor.
She asserted that, under the Property Registration Decree or, alternatively, Chapter VIII of Commonwealth Act No. 141 (1936), she and her predecessor-in-interest had maintained open, continuous, public, peaceful, and adverse possession “since time immemorial.”

Deed of Absolute Sale between Josephine Wee and Julian Gonzales (February 1, 1993).
Multiple tax declarations – in the name of Julian Gonzales (for the years 1957, 1961, 1967, 1980, and 1985) and in the name of Josephine Wee from 1993 onward.
Receipts for tax payments from 1993 to 1999.
Various affidavits including the Affidavit of Seller-Transferor, Affidavit of Ownership, Aggregate Land Holding and Non-Tenancy, and an Affidavit of Non-Tenancy executed on February 10, 1993.
A Salaysay executed by Juana Macatangay Gonzales, Erlinda Gonzales Batingal, and Remedios Gonzales Bayan.
A Certification by the DENR (dated March 2, 2000) confirming that Lot No. 8349 is within the Alienable or Disposable Land, with reference to the Land Classification Map established in 1982.
Survey Plan, Surveyor’s Certificate, Technical Description, and Tracing Cloth accompanying the application.

Josephine Wee testified on her immediate taking of possession after the sale, her payment of realty taxes, and the preparation of a survey plan. She mentioned that the property, planted with coffee, had no adverse claims against it.
Juana Gonzales, the 75-year-old widow of Julian Gonzales, confirmed that her late husband sold Lot No. 8349 to the petitioner and claimed that Julian was in possession of the property since at least 1946, having inherited it “a long time ago” from his parents.
Remedios Gonzales Bayan testified as a witness to the execution of the Deed of Absolute Sale and affirmed the authenticity of supporting documents (Salaysay).

On April 2, 2002, the RTC rendered a Judgment in favor of petitioner, holding that the evidence – including the deed of sale, tax declarations, payment receipts, and survey plans – sufficiently established her title and possession in fee simple.
The RTC observed that the parcel was duly declared for taxation, and that the possession, including tacking of predecessors’ acts, satisfied the conditions under the Land Registration Law.
The judgment approved the registration of the property under the applicable registration laws (Act 141, Act 496, and/or P.D. 1529).

The Republic, through the Office of the Solicitor General (OSG), filed a Notice of Appeal on April 26, 2002, challenging the RTC’s decision.
The main contention was that petitioner failed to establish possession—and specifically, open, continuous, exclusive, and notorious possession—since June 12, 1945, as required by law.
The CA reversed the RTC judgment, emphasizing the insufficiency of the evidence, notably the reliance on the deed of sale, recent tax declarations, and unsubstantiated claims regarding the coffee plantation.

Whether petitioner Josephine Wee established that she, together with her predecessor-in-interest, had been in open, continuous, exclusive, and notorious possession and occupation of Lot No. 8349 since June 12, 1945 or earlier.
Whether the documentary evidence (the Deed of Absolute Sale,-tax declarations, payment receipts, affidavits, survey plans, and other submitted papers) and witness testimonies were sufficient to prove her title and possession in fee simple.
Whether the physical evidence of a coffee plantation on the lot demonstrated effective acts of cultivation, development, and maintenance necessary to validate a claim of ownership under a bona fide possession.