Case Summary (G.R. No. 108926)
Applicable Law
The legal principles governing this case are primarily drawn from the 1987 Philippine Constitution and pertinent land registration laws, notably Presidential Decree No. 1529, which governs the registration of land titles in the Philippines.
Factual Background
The subject property measures 45,295 square meters and originally belonged to Santos de la Cruz, who declared ownership through several tax declarations from 1913 to 1921. Successive owners included Pedro Cristobal, Regino Gervacio, Diego Calugdan, and Gil Alhambra. An extrajudicial partition occurred following Alhambra's death, leading to a "Deed of Sale With Mortgage" executed on July 5, 1966, transferring ownership to the petitioner. Once the mortgage was released, the petitioner paid property taxes and declared the property in his name until 1986, when he filed a petition for registration of title.
Proceedings and Oppositions
The petition filed by the Republic of the Philippines alleged that the petitioner failed to demonstrate the necessary continuous possession required to establish ownership, opposing the claim based on tax declarations and earlier failed ownership claims. Several other oppositors also entered the proceedings, claiming rights to the property through historical titles and traditional possession.
Trial Court Decision
On June 14, 1991, the trial court ruled in favor of the petitioner, affirming his ownership based on evidence of continuous and notorious possession backed by tax declarations, indicating ownership for more than thirty years prior to June 12, 1945. The trial court's decision was rooted in the interpretation of possession in the concept of ownership, referring to the relevant tax records and witness testimonies.
Appeal and Court of Appeals Decision
The Republic appealed the trial court's decision asserting that the evidence presented was insufficient to support ownership claims. However, the Court of Appeals affirmed the trial court's ruling on February 8, 1993, agreeing that the petitioner's tax declarations and receipts constituted sufficient proof of continuous ownership and possession. The court found that the property had been transformed into a rice field, demonstrating actual possession, and rejected the opposing claims stating they lacked legal grounds.
Supreme Court Findings and Rulings
The Supreme Court rejected the Republic's petition, affirming the Court of Appeals' conclusion that the petitioner had proven ownership through legitimate claims of possession. The Court highlighted that merely withdrawing pr
...continue readingCase Syllabus (G.R. No. 108926)
Case Citation
- 328 Phil. 238; 93 OG No. 26, 3903 (June 30, 1997)
- G.R. No. 108926, July 12, 1996
Parties Involved
- Petitioner: Republic of the Philippines
- Respondents: Court of Appeals and Heirs of Democrito O. Plaza
Court Composition
- Decision Penalty: Associate Justice Torres, Jr.
- Concurring Justices: Regalado (Chairman), Romero, Puno, and Mendoza, JJ.
Procedural Background
- The petitioner seeks to review the decision of the Court of Appeals dated February 8, 1993.
- The Court of Appeals affirmed the Regional Trial Court's decision of June 14, 1991, which confirmed Democrito O. Plaza's title over the property in question.
- The petition was filed after parties submitted respective memoranda, with the petitioner submitting on June 29, 1993, and the private respondent on July 6, 1993.
Factual Background
- The property in question is located at Liwanag, Talon (formerly Pamplona), Las Piñas, Rizal, covering an area of 45,295 square meters.
- The history of the property shows it was originally owned by Santos de la Cruz, with tax declarations issued for various years (1913, 1917, and 1921).
- Successive owners included Pedro Cristobal, Regino Gervacio, Diego Calugdan, and Gil Alhambra.
- Upon Gil Alhambra's death, the heirs partitioned the property, which was sold to the petitioner on July 5, 1966, for P231,340.00, with a mortgage secured on the property.
- The petitioner took possession and paid taxes from 1966 to 1986, declaring it in his name in 1985.
Registration Petition
- On November 14, 1986, the petitioner filed a petition to register