Case Summary (G.R. No. 193305)
Background of the Case
In its initial ruling dated July 6, 2009, the Court of Appeals dismissed Banal na Pag-aaral's application for land registration due to its inability to prove that the land in question was alienable and disposable. This was a critical requirement for land registration under Philippine law. Following this dismissal, Banal na Pag-aaral filed a motion for reconsideration and supplied a Certification from the Department of Environment and Natural Resources (DENR), which stated that the subject land was indeed alienable and disposable.
Admission of New Evidence
The Court of Appeals, upon review, admitted the belatedly submitted Certification from the DENR, as the Office of the Solicitor General indicated no objection to its inclusion. This procedural aspect arose under the powers conferred to the Court of Appeals by Section 9 of Batas Blg. 129, as amended by R.A. No. 7902, allowing the court to receive evidence necessary for resolving factual issues, albeit within certain limitations particularly regarding appeals.
Limitations on Evidence Admission
It is established that in cases of appeal, the Court of Appeals’ authority to admit new evidence is limited to circumstances where it has granted a new trial. The general rule asserts that evidence not formally offered cannot be taken into consideration. In this instance, however, the Supreme Court recognized the exceptional nature of the submission, emphasizing that such certifications could be allowed in the interest of justice, provided the parties have opportunities to verify their authenticity and execution.
Remand for Further Proceedings
Consequently, the Supreme Court decided to remand the case back to the Court of Appeals. This remand is specifically aimed at determining the authenticity and due execution of the Certification submitted by Banal na Pag-aaral. The Court of Appeals is instructed to hear and receive further evidence from both parties
...continue readingCase Syllabus (G.R. No. 193305)
Case Overview
- This case involves a petition for land registration filed by Banal na Pag-aaral, Inc. against the Republic of the Philippines.
- The decision was rendered by the Second Division of the Supreme Court on February 5, 2018, under G.R. No. 193305.
- The Court of Appeals (CA) initially dismissed the application for land registration due to Banal na Pag-aaral's failure to prove that the land in question was alienable and disposable.
Initial Proceedings and Dismissal
- On July 6, 2009, the CA ruled against Banal na Pag-aaral, leading to the dismissal of its application for land registration.
- The basis for this dismissal was the insufficient proof of the land's status as alienable and disposable.
Motion for Reconsideration and New Evidence
- Following the dismissal, Banal na Pag-aaral filed a motion for reconsideration.
- In this motion, they provided a Certification from the Department of Environment and Natural Resources (DENR) asserting that the subject land was indeed alienable and disposable.
- The Office of the Solicitor General did not raise any objections to the late submissi