Case Summary (G.R. No. 173808)
Factual Antecedents
On March 12, 1993, Lourdes T. Jardeleza executed a Deed of Absolute Sale transferring ownership of a residential property to Fernanda Arbias for P33,000. Complete with documentation, Arbias filed a registration application in June 1996. The RTC examined the case, called witnesses, and allowed documents to establish the claim of ownership, ultimately ruling in favor of Arbias in June 2000.
Procedural History
The RTC of Iloilo City granted Arbias’ application, stating that her and her predecessors’ possession met legal requirements. However, the Solicitor General filed an appeal citing procedural issues and the inadequacy of evidence supporting Arbias' claim. The Court of Appeals ultimately dismissed Arbias’ registration application in a decision rendered on September 2, 2005, and later denied a motion for reconsideration on July 19, 2006.
Legal Issues Raised
Arbias raised several legal issues in her petition, including the assertion that the Office of the Solicitor General was estopped from contesting the RTC's findings due to lack of opposition during the trial. Moreover, she argued that the Court of Appeals erred in disregarding the RTC's conclusions based on witness demeanor and that the land ceased to be public after more than 30 years of possession.
Burden of Proof and Legal Framework
In Philippine land registration law, the Regalian doctrine establishes that all lands belong to the State unless proven otherwise. The applicant bears the burden of proving that the land is alienable and disposable and must show continuous possession. Pertinent to this case, Presidential Decree No. 1529 outlines the requirements for confirming imperfect titles, mandating proof of possession under a bona fide claim since June 12, 1945.
Court of Appeals Ruling
The Court of Appeals ruled that Arbias failed to substantiate her claims regarding possession and did not adequately demonstrate that the property was classified as alienable and disposable. The appellate court pointed out that the evidence presented, including tax declarations, did not constitute valid proof of ownership or claim sufficient to meet the standard required for land registration.
Petitioner’s Evidence Evaluation
The evidence Arbias provided did not convincingly show uninterrupted possession of the land for the requisite duration, as her own testimony indicated that she had only occupied the land for about six years. Tax declarations and the de
...continue readingCase Syllabus (G.R. No. 173808)
Case Overview
- The case involves a Petition for Review on Certiorari filed by Fernanda Arbias against the Republic of the Philippines, challenging the Decision and Resolution of the Court of Appeals dated September 2, 2005, and July 19, 2006, respectively.
- The Court of Appeals reversed the Regional Trial Court (RTC) of Iloilo City’s decision, which had granted Arbias's application to register a parcel of land under Presidential Decree No. 1529.
Factual Antecedents
- On March 12, 1993, Lourdes T. Jardeleza executed a Deed of Absolute Sale selling a parcel of unregistered land (Cadastral Lot No. 287) to Fernanda Arbias for P33,000.00.
- Arbias filed a verified Application for Registration of Title with the RTC on June 17, 1996, attaching various documents including a survey plan and tax declarations.
- The RTC ordered the initial hearing for February 17, 1999, during which the Office of the Solicitor General (OSG) entered an appearance and filed an Opposition to Arbias's application.
- The RTC conducted hearings where Arbias provided testimony and evidence of her ownership and possession. The OSG did not present counter-evidence but objected to the discrepancies in the land area.
RTC Decision
- On June 26, 2000, the RTC ruled in favor of Arbias, stating that the evidence presented, including the Deed of Sale and proof of continuous possession, constituted sufficient grounds for ownership and registration of the property.
Appeal to the Court of Appeals
- The OSG appealed the RTC's