Case Summary (G.R. No. 240475)
Antecedent Facts
The petitioners are the heirs of Amado Buenaventura and Irene Flores, who acquired the subject property from the heirs of Lazaro de Leon prior to World War II. A formal Deed of Sale was executed on January 30, 1948. Subsequently, a tax declaration was issued in the name of the spouses Buenaventura, establishing their ownership. The ownership was later transferred to the petitioners in a 1978 transaction.
Application for Title Registration
On June 5, 2000, the petitioners filed for registration of the title over the property. They claimed to have owned the land through inheritance and have possessed it openly and continuously. The Regional Trial Court (RTC) found their application sufficient, allowing the case to proceed to hearing, during which no opposition was raised by any interested parties.
RTC Decision
On October 29, 2001, the RTC granted the petitioners' application, recognizing their right to the land. The court ordered the issuance of a decree of registration in favor of the petitioners, effectively confirming their title to the property.
Appeal to the Court of Appeals
The Republic of the Philippines appealed the RTC's decision, contending that the petitioners did not prove the requisite duration of possession necessary for registration. The Court of Appeals upheld this argument and, on August 23, 2004, reversed the RTC's order, declaring the property as public land, thus invalidating the petitioners' claim.
Issues Raised
The petitioners contested the Court of Appeals' ruling on two primary grounds: first, the alleged failure to meet the requirement of substantial evidence for their claim of ownership; second, the declaration of the property as public land despite their evidence of long-standing possession.
Supreme Court Review
The Supreme Court undertook a re-examination of the facts and noted that the appeal could proceed due to recognized exceptions to the general rule that appellate courts' findings of facts are conclusive. The Court highlighted that the petitioners had indeed demonstrated substantial evidence of possession, which spanned over 30 years.
Examination of Legal Standards
Citing the Property Registration Decree, the Supreme Court discussed three essential requisites for registration: necessity of the property being alienable and disposable, requisite proof of open, continuous, exclusive, and notorious possession, and bona fide claim of ownership since June 12, 1945, or earlier. The Court embedded its analysis within the parameters set by the Regalian Doctrine.
Certification of Alienability
The petitioners supplied a certification from the Department of Environment and Natural Resources indicating the property was alienable and disposable. The Court reiterated the importance of such certifications in establishing the true nature of land and emphasized that the classification of the property as public land could be rebutted by sufficient evidence.
Requisite of Possession
Tho
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Case Background
- The petitioners, Angelita F. Buenaventura and Preciosa F. Buenaventura, filed a Petition for Review on Certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure.
- They sought to annul the Decision and Resolution of the Court of Appeals that reversed the Order of the Regional Trial Court (RTC) of ParaAque City, which had confirmed their title over a parcel of land.
- The RTC had recognized their rights over the property, declaring it registered in their names.
- The Republic of the Philippines, as the respondent, contended that the property in question was public land.
Antecedent Facts
- Petitioners are heirs of spouses Amado Buenaventura and Irene Flores, from whom they acquired the subject property.
- The spouses Buenaventura purchased the property from the heirs of Lazaro de Leon before World War II, with a formal Deed of Sale executed on January 30, 1948.
- Following the sale, the tax declaration was transferred to the spouses Buenaventura.
- The property was later transferred to the petitioners in 1978.
- The petitioners filed an application for registration of title on June 5, 2000, claiming ownership through inheritance and possession.
Initial Proceedings
- The RTC found the application sufficient and scheduled hearings.
- No interested parties opposed the application, leading the court to declare a general default, except for the Republic.
- The petitioners presented evidence, including testimonies from five witnesses, to establish their long-term possession and ownership claims.
RTC Order
- On October 29, 2001, the RTC granted the application for registration, c