Case Summary (G.R. No. 162322)
Procedural History
• 17 July 1997 – Respondent filed application for original registration before RTC (assessed value ₱14,920).
• 8 January 1998 – Republic filed Opposition while case was still with RTC.
• 31 March 1998 – Records transmitted motu proprio to MTC for lack of jurisdictional threshold at RTC level.
• 22 January 2001 – MTC entered default and granted registration.
• 13 February 2004 – CA affirmed MTC decision, applying estoppel by laches and finding sufficient proof of possession.
• 14 March 2012 – Supreme Court promulgated decision on Rule 45 petition.
Applicable Law
• 1987 Philippine Constitution, Article XII, Section 2 (Regalian Doctrine)
• Property Registration Decree (PD 1529), Section 23 (initial hearing periods)
• Judiciary Reorganization Act (BP 129, as amended by RA 7691), Section 34 (delegated jurisdiction of MTC)
• Rules on jurisdictional challenges and estoppel; Regalian doctrine requiring positive act of government to establish alienable/disposable land
Issues Presented
- Whether the Republic is estopped from challenging MTC’s delegated jurisdiction when raised for the first time on appeal.
- Whether the MTC properly acquired jurisdiction in light of prescribed periods for setting initial hearings and the value threshold for contested land registration.
- Whether a CENRO certification alone suffices to prove that the land is alienable and disposable public domain.
Analysis on Estoppel and Subject-Matter Jurisdiction
The Supreme Court reaffirmed that lack of subject-matter jurisdiction may be raised at any stage, even on appeal. The Tijam-exception for estoppel by laches applies only in unique cases of inordinate delay and active participation spanning many years. Here, the Republic timely opposed before jurisdiction shifted to the MTC and immediately raised the issue on appeal. No unreasonable neglect occurred; hence, no estoppel.
Analysis on Delegated Jurisdiction of the MTC
- Timing of Initial Hearing
– PD 1529 requires setting the initial hearing not earlier than 45 days nor later than 90 days from order issuance and issuance of that order within five days from application.
– The RTC’s initial setting beyond 90 days and delayed issuance of second order did not divest jurisdiction. Time limits are directory, not mandatory jurisdictional requirements. - Value Threshold
– Under RA 7691, MTC may hear contested land registration cases valued up to ₱100,000 ascertained by affidavit, claimant agreement, or tax declaration.
– No claimant’s affidavit or agreement exists; valuation rests on tax declarations showing total assessed value of ₱14,920, well below the ₱100,000 limit.
Analysis on Alienable and Disposable Character
While the MTC’s delegated jurisdiction is affirmed, registration requires proof that the land is alienable and dis
...continue readingCase Syllabus (G.R. No. 162322)
Facts
- On July 17, 1997, Bantigue Point Development Corporation (“respondent”) filed an application for original registration of title over Lot 8060, Cad. 453-D, San Juan Cadastre (≈10,732 sqm), Barangay Barualte, San Juan, Batangas.
- The total assessed value of the parcel, according to three tax declarations, was P14,920 (P4,330; P1,920; P8,670).
- On July 18 and August 7, 1997, the RTC of Rosario, Batangas issued orders setting the initial hearing on October 22 and November 4, 1997, respectively.
- The Republic of the Philippines (“petitioner”) filed its opposition on January 8, 1998, while the records remained with the RTC.
- On March 31, 1998, the RTC motu proprio transferred the records to the Municipal Trial Court (MTC) of San Juan because the assessed value was under P100,000.
- The MTC entered an order of general default on August 27, 1998, then commenced reception of evidence.
- Respondent presented Tax Declarations (Exhibits Q–BB, EE), a Deed of Absolute Sale (Exhibit CC), and a CENRO Batangas City certification (Exhibit K) that the land was within the alienable and disposable zone.
- On January 22, 2001, the MTC granted respondent’s application for registration.
- The Republic appealed to the Court of Appeals (CA) on February 12, 2001; the CA, on February 13, 2004, affirmed the MTC decision, applying estoppel by laches and finding respondent’s proof of open, continuous, exclusive, notorious possession sufficient.
- Petitioner filed a Rule 45 Petition for Review on Certiorari (G.R. No. 162322) before the Supreme Court on April 12, 2004.
Issues
- Whether the Republic is estopped from challenging the MTC’s jurisdiction for the first time on appe