Case Summary (G.R. No. 119288)
Key Dates
- April 22, 1955: Deed of sale from Cipriana Dantic-Llanera to Josefa Gacot (Exhibits 1 and 1-A)
- October 20, 1950: Prior CFI decision by Judge Lorenzo Garlitos declaring Lot 5367 to be government property
- June 7, 1971: Josefa Gacot filed her answer in the cadastral case
- September 5, 1990: RTC rendered judgment adjudicating Lot 5367 to Gacot
- August 12, 1993: RTC reaffirmed its earlier judgment after remand by the CA
- February 22, 1995: CA decision affirming the RTC’s judgment
- August 18, 1997: Supreme Court promulgation
Applicable Law
- 1987 Philippine Constitution (decision after 1990)
- Republic Act No. 931 (June 30, 1953) and Republic Act No. 2061 (June 30, 1958) time-bar provisions on reopening public-land proceedings
- Rules of Court: Rule 132, Sec. 34 (formal offer of evidence); Rule 129, Secs. 1–2 (judicial notice; liberal construction)
Procedural Background
- The RTC conducted cadastral proceedings, during which the Republic was represented by the Assistant Provincial Prosecutor and CENRO.
- Claimant (Gacot) appeared without counsel, asserted co-ownership with Ceferino Sabenacio, and presented evidence of purchase, continuous possession, tax declarations, and payments since 1955.
- The government elected not to present controverting evidence at initial hearing; the RTC adjudicated Lot 5367 to Gacot on September 5, 1990.
- The Republic appealed to the Court of Appeals. During appeal, the CA remanded to the RTC to allow the Republic to offer the 1950 judge’s order declaring Lot 5367 government property.
- On remand, the government again failed to present the Garlitos order or witness testimony; the RTC on August 12, 1993 reaffirmed its prior adjudication.
- The CA on February 22, 1995, affirmed the RTC’s decision in toto.
Factual Findings
- Josefa Gacot acquired Lot 5367 by deed of sale in April 1955, continuously occupied and improved the land, and paid real-estate taxes under her name.
- Ceferino Sabenacio, initially alleged co-owner, waived his claim in favor of Gacot.
- The Republic accepted tax payments up to the present and did not object to claimant’s occupation at hearings or via local officials.
- A 1950 CFI decision declaring Lot 5367 government property existed but was not formally offered in evidence at the rehearing.
Issues on Appeal
Whether the CA erred in ruling that the Republic could not invoke RA 2061’s time bar—and that the RTC lacked jurisdiction—because the Republic failed to formally offer the October 20, 1950 order declaring Lot 5367 as government property.
Court of Appeals’ Rationale
- RA 2061 imposes a December 31, 1968 deadline for reopening judicial proceedings on public land; Gacot’s June 1971 answer was beyond that period.
- The CA found the Republic failed to formally offer the 1950 order at the rehearing; under Rule 132, Sec. 34, evidence not formally offered cannot be considered.
- Judicial notice of the 1950 order was not permitted, as courts may not take notice of records in other cases.
- Because the Republic did not present any evidence at rehearing, the CA affirmed the RTC’s judgment.
Supreme Court Ruling
- The petition for certiorari is granted in part; the CA’s legal principles are correct but warrant careful application.
- The technical rule that evidence must be formally offered (Rule 132, Sec. 34) should yield where substantive justice demands—and where the Republic requested remand to present the 1950 order.
- Under Rule 129, Sec. 1, courts must take judicial notice of official acts and record ...continue reading
Case Syllabus (G.R. No. 119288)
Facts of the Case
- Lot No. 5367 is situated in Barangay Los Angeles, Magsaysay, Palawan; its exact area was not initially indicated in the cadastral records.
- On June 7, 1971, private respondent Josefa Gacot filed her answer in Cadastral Case No. 13, claiming the entire lot; she appeared in person without counsel.
- Records show Ceferino Sabenacio as alleged co-owner; he later waived any claim, stating he was only a boundary owner.
- A 1950 decision by Judge Lorenzo Garlitos declared Lot No. 5367 as property of the Republic of the Philippines—but neither the Republic nor its agents interposed objection nor prevented Gacot’s filing, possession, occupation, or tax declarations.
- Gacot’s evidence:
• Married to Vicente Dantic, Sr. in 1940; in continuous, public, and notorious possession for over 30 years.
• Deed of sale dated April 22, 1955, purchasing from Cipriana Dantic-Llanera (Exhibits 1, 1-A).
• Introduced improvements, declared the lot for taxation (Exhibit 2), and paid taxes up to the present (Exhibit 3).
• Five children: Hernando, Antero, Felipe, Fe, and Vicente Jr. - During the hearing on August 9 and 13, 1990, the Republic’s representatives—Assistant Provincial Prosecutor Reynaldo Guayco and CENRO Rogelio Paglinawan—failed to present any controverting evidence; they rested without offering the 1950 decision.
Procedural Antecedents
- Trial court (Branch 50, RTC Palawan) set hearings in August 1990; upon the Republic’s failure to oppose, on September 5, 1990, it rendered judgment adjudicating Lot 5367 to Gacot, subject to estate tax.
- The Republic, through the Solicitor General, appealed to the Court of Appeals (CA).
- On December 26, 1991, the CA granted the Republic’s motion for remand, ordering the trial court to reopen proceedings so the Republic could present Judge Garlitos’s 1950 order.
- At the rehearing before the RTC, the Republic again did not present witnesses or the 1950 decision; Gacot submitted a memorandum, while the Republic filed none.
- On August 12, 1993, the RTC affirmed its origin