Case Summary (G.R. No. 45828)
Procedural Background
The private respondents filed an application on January 29, 1973, seeking registration of two parcels of land under Act 496, which are portions of Lot 2749 of the Orion Cadastre. In response to a Court order, a report was submitted indicating that the parcels were subject to prior registration proceedings, although records had been lost due to war. The Director of Lands opposed the application, asserting that the respondents failed to establish ownership due to insufficient possession and claim that the land was public domain.
Evidence Presented
During the hearings, private respondents attempted to prove their claim of ownership through testimonies from two witnesses, Crisanto Angeles and Monico Balila. Angeles claimed to have possessed the land since 1931, cultivating it and declaring it for taxation purposes in 1966. Balila, an adjoining landowner, attested to witnessing Angeles's possession of the land. It was also noted that the parcels had been declared for taxation by the respondents since they acquired them.
Court Decisions
The lower court ruled in favor of the private respondents on April 6, 1974, confirming their titles to the parcels and ordering the issuance of a decree of registration. The Director of Lands appealed, arguing that the defense of res judicata had been waived by not being raised in the initial stages of the proceedings and contended that the decision derived from the cadastral proceedings barred any subsequent confirmation on the basis of possession.
Findings on Res Judicata
The Court of Appeals, in its decision dated May 7, 1977, confirmed the lower court's findings and ruled that the defense of res judicata was not valid since it was not raised in the original pleadings. The court found that the private respondents successfully demonstrated the requisite thirty-year period of continuous possession. The Court ruled that a prior decision in a cadastral proceeding declaring land public did not necessarily preclude subsequent claims if those claims were grounded in adverse possession, provided they complied with the relevant provisions of law.
Supreme Court's Assessment
In evaluating the appeals, the Supreme Court revisited the evidentiary standards and procedural conduct emphasized by the Court of Appeals. It found doubts regarding the provenance of the testimonies supporting the private respondents' claims, particularly how Crisanto Angeles w
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Case Overview
- This case involves a petition for review on certiorari filed by the Director of Lands against the respondents Silvestre Manlapaz and Natividad Pizarro, challenging the decision of the Court of Appeals which upheld the ruling of the lower court regarding the registration of two parcels of land.
- The decision from the Court of Appeals, dated March 7, 1977, affirmed the lower court's order confirming the titles of the properties in favor of the private respondents.
Facts of the Case
- On January 29, 1973, spouses Manlapaz and Pizarro filed an application to register two parcels of land under Act 496 and Section 48 (B) of C.A. No. 141, designated as Lot No. 2855 and Lot No. 2856.
- The parcels, located at Barrio Damulog, Orion, Bataan, have areas of 49,954 sq. meters and 54,052 sq. meters, respectively.
- Prior to the hearing, the trial court ordered a report from the Land Registration Commissioner to determine if the parcels had existing patents or pending decrees.
- A report indicated that the parcels were part of Lot 2749, which had previously undergone registration proceedings, but records were lost due to war.
Opposition from the Director of Lands
- The Director of Lands opposed the application, arguing that the private respondents lacked sufficient title and had not shown the required 30 years of continuous possession.
- He contended that the land was public domain and not subject to private appropriation.
Hearing and Evidence Presentation
- During the August 21,