Case Summary (G.R. No. 195636)
Facts of the Case
On September 10, 2002, the petitioners filed for original registration of the land under Presidential Decree (P.D.) No. 1529. They claimed to own a 2,815-square meter parcel of land, asserting peaceful possession and full ownership without any adverse claims. The Republic opposed the application, arguing that the petitioners had not established the requisite continuous and exclusive possession since June 12, 1945.
Opposition by the Republic
The Republic, through the OSG, contended that spouses Manzana failed to provide credible evidence of possession dating back to the date specified in the law, and highlighted that the land remained part of the public domain, thus not subject to private appropriation. They also pointed to discrepancies in the land’s survey documentation.
Testimony and Evidence Presented
During the proceedings, the Manzanas presented testimonies aimed at establishing their claim. Key witnesses included Sonia Manzana and Jeriel B. Villanueva, the latter claiming that his mother had owned the land prior to its sale to the spouses. Furthermore, Engineer Ricardo Nilo of the LRA provided evidence concerning discrepancies in the land's survey and confirmed that the subject land's status regarding ownership and registration was still under verification.
MTC Ruling
The Municipal Trial Court (MTC) ruled in favor of the Manzanas, declaring them the lawful owners of Lot 5653 and issuing the corresponding Decree of Registration. This judgment was based primarily on the evaluation that the petitioners had proven ownership and peaceful possession of the land.
Court of Appeals (CA) Ruling
The CA reversed the MTC’s ruling, asserting that although evidence indicated the land was alienable and disposable, the Manzanas did not demonstrate they've continuously possessed the property as required under Section 14(1) of P.D. No. 1529. The court emphasized that tax declarations and some testimonial evidence were insufficient to substantiate possession since June 12, 1945.
Issues Submitted for Resolution
The primary issue presented was whether the CA committed an error in reversing the MTC’s ruling and dismissing the registration application. The petitioners maintained that they satisfied the legal requirements necessary for the land registration, while the respondent underscored that the Manzanas had not met the possession requirements as mandated by law.
Court's Ruling and Conclusion
The Supreme Court ruled that the OSG properly appealed the MTC's
...continue readingCase Syllabus (G.R. No. 195636)
Background and Procedural History
- The case involves an Application for original registration of land under Presidential Decree No. 1529 (Property Registration Decree) filed by spouses Dante and Sonia Manzana before the Municipal Trial Court (MTC) of Morong, Rizal acting as a Land Registration Court.
- The MTC initially ruled in favor of spouses Manzana confirming their ownership of Lot 5653, Psc-16, Morong Cadastral.
- The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed the application contesting the open, continuous, exclusive and notorious possession requirement and the alienable/disposable character of the land.
- The Land Registration Authority (LRA) reported discrepancies in the survey plan and initially did not recommend approval pending verification from the Department of Environment and Natural Resources (DENR).
- Upon DENR’s subsequent confirmation that the property was not in doubtful position, the MTC granted the application.
- On appeal, the Court of Appeals (CA) reversed the MTC Decision, holding that spouses Manzana failed to prove open, continuous, exclusive and notorious possession since June 12, 1945, and that the property remained part of the public domain.
- The CA also ruled that there was still doubt regarding the technical description due to pending verification by the DENR.
- The petition for review on certiorari challenges the CA decision.
Facts of the Case
- Spouses Manzana claimed ownership of a 2,815-square meter parcel Lot 5653 by Deed of Sale from Caridad Bonifacio.
- They alleged peaceful occupation and possession since acquisition.
- Three witnesses testified: the spouse Sonia Manzana, Jeriel Villanueva (son of previous owner), and Engineer Ricardo R. Nilo from the LRA.
- Engineer Nilo testified on survey discrepancies and initial findings that the lot was in doubtful position, later corrected upon receipt of DENR’s certification.
- The DENR certified the land as part of alienable and disposable lands without doubt in the position with respect to adjacent lots.
- The Community Environment and Natural Resources Office (CENRO) also certified that the property fell within alienable and disposable land since 1927.
- The MTC directed spouses Manzana t