Case Summary (G.R. No. 197733)
Case Overview
- Case Citation: 839 Phil. 332 (2018)
- Parties Involved: Samuel and Edgar Buyco (Petitioners) vs. Republic of the Philippines (Respondent)
- Court: Supreme Court of the Philippines
- Date: August 29, 2018
- Nature: Petition for Review on Certiorari under Rule 45 of the Rules of Court
Background and Procedural History
- The petitioners filed for land registration of a parcel known as Lot 1, Psu-127238, encompassing approximately 3,194,788 square meters located in Romblon.
- Initial application occurred on October 14, 1976, and was granted on February 5, 1985, but was reversed by the Court of Appeals (CA) due to res judicata, asserting that previous decisions rendered the matter settled.
• The original application was contested by the Director of Lands, citing the petitioners' American citizenship as disqualifying under the Constitution. • The Supreme Court dismissed the initial registration in G.R. No. 91189, stating the lack of proof of alienability and disposability of the land.
Legal Principles
Res Judicata
- Definition: Legal doctrine preventing re-litigation of issues already judged.
- Application: The CA held that all elements of res judicata were present since the earlier case was decided with finality.
• The petitioners' claims were dismissed as the CA deemed the issues settled. • The finality of judgments renders previous claims non-justiciable.
Evidence Requirements for Land Registration
Alienable and Disposable Lands
- Key Requirement: To register land, applicants must prove it is alienable and disposable.
- Necessary Documentation:
- Copy of the original classification approved by the DENR Secretary.
- Certification of land classification status from CENRO or PENRO.
• The petitioners presented insufficient evidence, relying heavily on certifications rather than the required original classifications. • The court emphasized that grazing lands are typically inalienable under Philippine law.
Court's Ruling
- The Supreme Court upheld the CA's decision, affirming the dismissal of the petitioners' application for land registration without prejudice.
- The Court found that the evidence presented did not meet the burden of proof required to classify the land as alienable and disposable.
• The petition was denied, confirming the CA's ruling.
Key Takeaways
- The Supreme Court reinforced the doctrine of res judicata in land registration cases, emphasizing that prior final judgments must be respected.
- The burden of proof remains on applicants to demonstrate that land is alienable and disposable, necessitating specific documen
Case Syllabus (G.R. No. 197733)
Case Background
- The case involves a Petition for Review on Certiorari filed under Rule 45 of the Rules of Court by Samuel and Edgar Buyco against the Republic of the Philippines.
- The petition seeks to reverse the Decision dated January 26, 2011, rendered by the Court of Appeals (CA) in CA-G.R. CV No. 68708, which overturned the Regional Trial Court's (RTC) decision granting the petitioners' application for land registration over a large parcel of land.
- The land in question is described as Lot 1, Psu-127238, located in barrios Canduyong, Anajao, and Ferrol, Tablas, Romblon, with an area of approximately 3,194,788 square meters.
Facts and Antecedent Proceedings
- On October 14, 1976, the Buyco brothers, through their attorney-in-fact, filed for land registration with the Court of First Instance of Romblon, which was later docketed as LRC Case No. N-48.
- The Republic, through the Director of Lands, opposed the application, arguing various points, including the alleged disqualification of the applicants due to their American citizenship.
- The RTC ruled in favor of the Buycos on February 5, 1985, granting their application for registration.
- The Republic appealed the decision, claiming that the Buycos were barred from registration due to their citizenship status and the presumption that the land was public land.
- The CA dismissed the appeal on November 21, 1989, but the Supreme Court later reversed the RTC's de