Case Summary (G.R. No. 141001)
Applicable Law
This decision is governed by the 1987 Philippine Constitution and pertinent legislation such as the Property Registration Decree (Presidential Decree No. 1529) and Commonwealth Act No. 141, as amended. These statutes provide the framework for land registration processes, specifically outlining the necessary proofs required for establishing ownership and land classification.
Factual Background
On June 4, 1998, the Petitioner filed an application for the registration of three parcels of land with a total area comprising 96,292 square meters. These properties were claimed to have been purchased by the Petitioner from various sellers on August 28, 1989. The land had been declared for taxation purposes on August 9, 1989, and the Petitioner asserted possession and cultivation of agricultural crops on the land since acquisition.
Initial Trial Court Ruling
The Regional Trial Court (RTC) of Pasig City, on November 27, 2001, granted the Petitioner’s application, finding that the Petitioner was the "absolute owner in fee simple" of the properties. This ruling was based on the evidence presented by the Petitioner, including testimonies asserting continuous and exclusive possession since the acquisition date.
Appeal and Court of Appeals Decision
Dissatisfied with the RTC’s ruling, the State appealed the decision to the Court of Appeals (CA), citing substantial and procedural defects in the application. The CA, in its decision dated May 23, 2008, reversed the RTC ruling, dismissing the application on the grounds that the identity of the subject properties was not convincingly established and that provisions regarding the declaration of the properties as alienable and disposable were unfulfilled.
Requirements for Land Registration
The decision emphasized key requirements for land registration: the applicant must prove the properties are alienable and disposable, demonstrate clear continuous and exclusive possession under a bona fide claim of ownership since June 12, 1945, or prior. The CA ruled that the Petitioner failed to meet these requirements, specifically regarding the alienability of the land.
Burden of Proof
The Court reiterated the principle that the burden of proof lies with the applicant in establishing that the subject properties are indeed alienable and disposable, noting that mere certifications from the Community Environment and Natural Resources Office (CENRO) do not suffice without further, specific documentation indicating governmental
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Background of the Case
- This case involves a petition for review on certiorari filed by Remman Enterprises, Inc. (petitioner) under Rule 45 of the Rules of Court.
- The petitioner is assailing the Decision dated May 23, 2008, and Resolution dated June 22, 2009, of the Court of Appeals (CA) in CA-G.R. CV No. 74418.
- The CA reversed an earlier Decision dated November 27, 2001, of the Regional Trial Court (RTC) of Pasig City, Branch 155, which had granted the petitioner’s application for land registration of three parcels of land situated in Taguig, Metro Manila.
Facts of the Case
- The petitioner, represented by Ronnie P. Inocencio, filed an application for registration on June 4, 1998, for three parcels of land located in Barangay Napindan, Taguig, Metro Manila, with areas of 27,477 sq m, 23,179 sq m, and 45,636 sq m.
- The properties were purchased on August 28, 1989, from sellers Magdalena Samonte, Jaime Aldana, and Virgilio Navarro and were declared for taxation purposes on August 9, 1989.
- After the acquisition, the petitioner cultivated the land, planting crops such as rice, corn, and vegetables.
- Cenon Serquina, a witness, testified that he had been the caretaker of the properties since 1957 and claimed no other parties had asserted ownership over the properties.
RTC Decision
- On November 27, 2001, the RTC granted the petitioner's application, declaring the petitioner the absolute owne