Case Summary (G.R. No. 166890)
Background Facts
Apolonio Bautista, Sr. acquired Lot 17078 from Mario Jardin and Cornelia Villanueva in 1971 and 1973, respectively. Following his acquisition, he possessed the property exclusively until his death in 1987. Upon his passing, his children, including Apolonio, Jr., executed an extrajudicial settlement that resulted in the declaration of the property under Apolonio, Jr.’s name for tax purposes, with no outstanding real estate taxes. On October 21, 1996, Apolonio, Jr. initiated an application for judicial confirmation of his title to the property at the Municipal Trial Court.
Proceedings at Lower Courts
In the trial, Apolonio, Jr. testified regarding the possession and ownership of the property, providing evidence that included notarized deeds of sale and tax declarations. The Municipal Trial Court admitted his evidence without objection from the Government, which did not contest any of his assertions during the trial. The MTC eventually ruled in favor of Apolonio, Jr., confirming his ownership of the land. The Government’s subsequent appeal to the Court of Appeals led to the affirmation of the MTC’s decision.
Legal Arguments Presented
In its appeal, the Government contended that Apolonio, Jr.'s testimony was hearsay and thus lacked probative value. It asserted that the judicial confirmation of public land necessitates adherence to stringent legal requirements, particularly that the applicant must prove possession since June 12, 1945, or earlier, as stated in Section 48(b) of Commonwealth Act No. 141, as amended by Presidential Decree No. 1073. The Government criticized the sufficiency of the evidence presented by Apolonio, Jr., arguing that tax declarations and general statements regarding possession were inadequate to establish ownership.
Court Rulings and Legal Analysis
The Court ultimately ruled in favor of the Government, reversing the previous decisions and dismissing Apolonio, Jr.'s application for judicial confirmation of imperfect title. The Court emphasized the necessity for the applicant to demonstrate that the possession of the property was established since June 12, 1945, or earlier, in alignment with legal stipulati
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Case Overview
- The case involves a petition for review on certiorari by the Republic of the Philippines against Apolonio Bautista, Jr.
- The Supreme Court reversed the decision of the Court of Appeals, which had previously affirmed the Municipal Trial Court’s ruling granting Apolonio Jr. judicial confirmation of imperfect title for Lot 17078 of Cad. 547-D, Subic Cadastre.
Background of the Case
- Apolonio Bautista, Jr. sought judicial confirmation of ownership over Lot 17078, having acquired the property through his deceased father, Apolonio Bautista, Sr., who purchased it from Mario Jardin and Cornelia Villanueva in 1971 and 1973, respectively.
- Apolonio Sr. was the sole possessor and occupant of the land until his death in 1987, with no claims against his ownership or possession.
- Following their father's death, Apolonio Jr. and his siblings executed an extra-judicial settlement favoring him, leading to the property being declared under his name for tax purposes.
Judicial Proceedings
- Apolonio Jr. filed LRC Case No. N-12-10-96 on October 21, 1996, in the Municipal Trial Court (MTC).
- He testified regarding his father’s possession of the land since 1969 and presented deeds of absolute sale and tax declarations as evidence.
- The Government did not object to his testimony or the evidence presented, leading the MTC t