Case Summary (G.R. No. 243133)
Applicable Law
The case revolves around Section 48(b) of the Public Land Law, as amended by Republic Act No. 1942, which pertains to properties that are registerable for land titles.
Background of the Application
The application pertains to 291 hectares of land adjacent to the Sorsogon-Albay national highway, which the Court of Appeals initially denied in 1977 but later reversed in 1979, ultimately leading to an appeal by the Director of Lands. The core issue is the land's status as alienable and disposable, declared as such only in 1961.
Chain of Title and Sale Transactions
Evidence indicates that in 1952, Tomas Cevallos and his sister sold the land to Soledad Fajardo Vda. de Salazar without clear proof of ownership or Spanish title. Subsequently, in 1965, Mrs. Salazar sold the land to her four children, who then sought registration. However, claims of long-standing ownership were disputed.
Occupation and Improvements
The Salazar family claimed that the land had been cultivated and occupied by an overseer, Nicolas Millevo, but failed to provide proof of his possession or to substantiate their claim of being rightful owners. The application was met with opposition from various individuals claiming to have occupied the land for years.
Evidence from Land Inspector
A report by Land Inspector Baldomero Esperida recommended opposing the application, detailing that the land was cultivated and occupied by various farmers, who had been in possession of it acting as owners, thus indicating a long-standing occupation prior to the Salazar family's claim.
Testimonies and Claims
The testimonies from several farmers living on the land established a claim of long-term possession. Many farmers, raised on or near the land, resisted the Salazar family's claims, asserting that they felt a stronger right to the land based upon their familial and longstanding occupancy.
Legal Findings on Land Classification
The appellate court noted the legal error in granting the application, pointing out that the Salazars could not establish possessory rights prior to April 28, 1961, when the land was declared alienable and disposable. Their reliance on earlier occupancy was legally irrelevant.
Clarity on Tax Documentation
The documentation provided b
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Case Overview
- This case involves an application for the registration of 291 hectares of land located adjacent to the Sorsogon-Albay national highway in Barrios Salvacion and Esperanza, Pilar, Sorsogon.
- The Court of Appeals initially denied the application in a decision rendered in 1977 but later reversed itself and granted the application in 1979.
- The Director of Lands appealed to the Supreme Court, raising the primary issue of whether the land is registerable under section 48(b) of the Public Land Law, as amended by Republic Act No. 1942.
Background of the Case
- The land in question was declared alienable and disposable by the Director of Forestry only on April 28, 1961.
- The applicants, Tomas Cevallos and his sister Alberta Cevallos, sold the land to Soledad Fajardo Vda. de Salazar for P50,000 on March 13, 1952. However, the deed of sale did not specify how the Cevalloses obtained ownership of the land.
- On July 30, 1965, Mrs. Salazar sold the five lots to her children, Jose, Jesus, Pedro, and Aurora Salazar, for a reduced price of P20,000.
Evidence and Tax Declarations
- The Salazar siblings obtained tax declarations indicating the assessed value of the land, but the majority of the area was uncultivated or classified as cogon land.
- The 1965 tax declarations revealed that approximately 96 hectares were cultivated with crops, while the remaining 195