Title
Spouses Dante Sj. Manzana and Sonia R. Manzana vs. Republic
Case
G.R. No. 195636
Decision Date
Nov 6, 2023
Spouses Manzana's application for land registration was denied by the CA for failure to prove required possession and ownership since 1945, which the SC remanded for further proceedings under new possession requirements.
land registration
public domain
ownership
A

Case Summary (G.R. No. 195636)

Factual Background

On September 10, 2002, spouses Manzana filed before the MTC, acting as a Land Registration Court, an Application for original registration under P.D. No. 1529. They alleged ownership of a 2,815-square meter parcel designated as Lot 5653, that the land had been surveyed and that the corresponding plan had been approved. They also claimed an assessed value of PHP 6,640.00 under Tax Declaration No. 02-2339-A and asserted that, to their knowledge, there were no mortgages or encumbrances affecting the land. They further stated that they acquired the land from Caridad Bonifacio by Deed of Sale, and that they and their predecessors had maintained peaceful, public, quiet, and continuous possession in the concept of owner without adverse claim.

The Republic, through the OSG, filed an Opposition. It contended that spouses Manzana had not been in open, continuous, exclusive and notorious possession of the land since June 12, 1945 or earlier. It also argued that tax declarations and other muniments were not competent and sufficient evidence of bona fide acquisition, that the applicants could not rely on claims based on old Spanish title or grant because of failure to file within the required period under P.D. No. 892, and that the parcel remained a portion of the public domain not subject to private appropriation.

LRA Findings and the “Doubtful Position” Issue

During the proceedings, the Land Registration Authority (LRA) submitted a Report dated March 18, 2003 noting a discrepancy when the plan was plotted on the municipal index sheet. The LRA explained that when the plan for Lot 5653 was plotted through its tie line, it showed a doubtful position with respect to adjoining lots previously applied for in LRC Record Nos. N-51286 and N-57108.

Spouses Manzana offered testimonies of three witnesses. Sonia R. Manzana testified to support the material allegations in the application. Jeriel B. Villanueva testified that the subject property was owned by his mother, Caridad Bonifacio, and that his mother sold it to spouses Manzana in April 1990; he stated that before the sale, his mother had peaceful possession without disturbance, and he testified that as early as age seven he was aware of a tenant, Cesario San Agustin, who brought harvests from the property. Engineer Ricardo R. Nilo, an LRA examiner, testified that LRA records were similar to those submitted to the MTC and that they compared the blueprint copy with the tracing cloth plan.

However, during cross-examination, Engr. Nilo explained that his office’s initial technical examination placed the subject land in a doubtful position because it did not align with the adjacent lands when plotted in the sky land. He clarified that the doubtful position related to the adjoining lands and that the LRA was requesting the cadastral map for reference from the DENR. Engr. Nilo also stated that because of this, the LRA did not recommend approval pending further cadastral verification.

Consistent with that, the LRA sent a letter to the Department of Environment and Natural Resources (DENR) dated March 18, 2003, requesting verification and correction of the discrepancy and seeking technical descriptions and cadastral map information to project Lot 5653 for record purposes. Engr. Nilo later testified that the LRA still withheld recommendation because it was awaiting the cadastral survey.

DENR later issued a Reply dated May 26, 2003 stating that the subject land was “not in a doubtful position” with respect to Lots 5651 and 5650, and it furnished a reproduction copy of the cadastral map and certified lot data computations for the other lots. Nonetheless, the record showed that no copy of the cadastral map nor the certified lot data computations for the relevant lots were submitted to the MTC. Years later, on May 10, 2006, Engr. Nilo testified again and stated that, based on the DENR reply, the LRA concluded that the doubtful position remarks were already corrected and that the property could be registered. He explained that the LRA’s earlier computation had shown a doubtful position due to insufficient references, but that the later inclusion of additional references led to the conclusion that the property was not in a doubtful position.

The Community Environment and Natural Resources Office (CENRO) also submitted a report dated in evidence, certifying that the subject land fell within the Alienable and Disposable zone under Land Classification Map No. 639 per Project No. 16, certified released on March 11, 1927.

Additionally, on May 21, 2008, the MTC received a letter dated April 25, 2008 from the LRA requesting the applicants to submit copies of the plan and technical description to DENR-Region IV for verification of the status of the subject lots. On May 22, 2008, the MTC directed spouses Manzana to submit the requested documents. Soon thereafter, the MTC rendered the decision that granted the application.

Trial Court Proceedings and MTC Ruling

In its Decision dated June 25, 2008, the MTC granted spouses Manzana’s application. It declared and confirmed ownership in favor of the applicants over Lot 5653, Psc-16, Morong Cadastre and ordered issuance of the corresponding decree of registration upon finality of the decision, subject to compliance with Section 39 of P.D. No. 1529.

The Parties’ Contentions in the CA

The Republic, through the OSG, appealed to the CA. In its Decision dated June 28, 2010, the CA reversed and set aside the MTC ruling.

The CA accepted that spouses Manzana presented proof that the property was alienable and disposable, citing the DENR-Region IV/CENRO report. Nevertheless, the CA held that spouses Manzana failed to prove that they had been in open, continuous, exclusive and notorious possession and occupation since June 12, 1945, as required by Section 14(1) of P.D. No. 1529. The CA further stated that spouses Manzana could not rely on Section 14(2) because the land remained part of the public domain and was not shown to be of patrimonial character. The CA also found that the evidence failed to establish that the predecessor-in-interest had the requisite possession to warrant registration under Section 14(2).

Finally, the CA concluded that doubt still existed in the technical description of the property. It noted that, even after Engr. Nilo testified that the doubtful position had been corrected, the LRA still requested that documents be submitted to DENR to verify the status of the lot. According to the CA, this undermined the veracity of Engr. Nilo’s testimony and the DENR letter dated May 26, 2003. The CA held that the MTC should have waited for the final verification from DENR before deciding.

Spouses Manzana moved for reconsideration, but the CA denied it in a Resolution dated September 14, 2010.

Issues Presented to the Supreme Court

Spouses Manzana filed the petition for review on certiorari. The principal issues were whether the CA erred in (1) reversing the MTC decision that granted registration and (2) doing so effectively by requiring strict proof of possession under the pre-amendment Section 14(1) standard.

Spouses Manzana argued that they met the requirements of Section 14(1) by showing that the predecessor-in-interest had been in open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier. They relied on tax declaration notations, particularly that a tax declaration registered in December 1948 had a notation canceling a previous tax declaration under the predecessor’s name, which they treated as evidence that the property was declared in that earlier period. They also argued, in the alternative, that if the specific June 12, 1945 timeline was not proven, they still qualified under Section 14(2) due to acquisitive prescription through the required character and duration of possession by themselves and their predecessor. They further contended there was no doubt in the technical description that should prevent registration. Additionally, they argued that the OSG’s appeal should have been filed before the Regional Trial Court (RTC) rather than directly before the CA.

The Republic, through the OSG, maintained that spouses Manzana raised essentially questions of fact, which are not proper for a petition under Rule 45, and that the CA correctly ruled that the evidence did not establish full compliance with the substantive requirements for registration.

Procedural Ruling on the OSG’s Appeal and Scope of Review

The Court first addressed whether the Republic correctly appealed the MTC decision directly to the CA. It held in the affirmative, consistent with the CA’s view, because the MTC rendered the appealed decision in the exercise of delegated jurisdiction in cadastral and land registration cases. Under Section 34 of the Judiciary Reorganization Act of 1980, as amended by R.A. No. 7691, MTC decisions in such delegated jurisdiction were appealable in the same manner as RTC decisions.

The Court then addressed the OSG’s contention regarding factual issues. It recognized the general rule under Rule 45, Section 1 that petitions raise only questions of law, and that the Court is not normally a trier of facts. It nevertheless recognized exceptions, including when the CA’s findings are contrary to those of the trial court. The Court treated the case as falling within this exception because the CA reversed the MTC ruling on substantive grounds.

Legal Basis and Reasoning: Impact of R.A. No. 11573 and Pasig Rizal Guidelines

On the merits, the Court reiterated the settled requirements under Section 14(1) of P.D. No. 1529 for granting an application for registration: the land must be part of the alienable and disposable lands of the public domain, and the applicant must show that the land, by itself or through predecessors, had been in open, continuous, exclusive and notorious possession under a bona fide claim of ownership since June 12, 1945 or earlier.

While the case was pending, R.A. No. 11573 was enacted and took effect on

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