Case Summary (G.R. No. L-41518)
Issue Presented
Whether the State sufficiently proved that, at the time of the cadastral decree and issuance of title to Espinosa, the property formed part of inalienable forest land.
Supreme Court Ruling
Burden of Proof and Presumption of Title
- A cadastral decree and Torrens title carry the presumption of regularity and that the land is alienable and disposable.
- In a reversion case, the affirmative burden lies on the State to prove that the land was misclassified and belonged to public domain at the time of registration.
Formal Offer and Admissibility of LC Map No. 2978
- Documentary evidence must be formally offered to satisfy due process and allow opposition.
- The State failed to formally offer or authenticate the 1986 land classification map under Rule 132, Sec. 24; the trial court erred in considering it.
- Even if admitted, the map only shows reclassification in 1986, not at the 1955–62 period when Espinosa obtained the cadastral decree and OCT.
Effect of Subsequent Reclassification
- Subsequent land classification cannot invalidate an earlier valid decree and title without violating due process and just compensation.
- Citing Sta. Monica Dev’t Corp. v. CA and SAAD Agro-Industries, Inc. v. Republic, the Court emphasized that private rights matured before later reclassification must be respected.
Legal Principles Applied
- Regalian Doctrine: All lands of the public domain belong to the State, but valid Torrens titles issued after proper cadastral proceedings defeat subsequent reclamation.
- Reversion Remedy: Available only where fraud, mistake, or lack of jurisdiction taints the original award; mere reclassification post-registration is insufficient.
- Due Process: Formal offer and authentication of evidence are indispensable even against the Government; failure renders e
Case Syllabus (G.R. No. L-41518)
Procedural History
- Petition for review on certiorari filed by the Republic of the Philippines before the Supreme Court under G.R. No. 186603, assailing the Court of Appeals’ (CA) July 25, 2008 Decision and February 4, 2009 Resolution in CA-G.R. CV No. 00421.
- The CA had modified the Regional Trial Court’s (RTC) May 12, 2004 Decision, affirming the validity of OCT No. 191-N and TCT No. 91117 and the award of damages in favor of Caliston.
- The Supreme Court Third Division, through Justice Jardeleza, resolved the petition on April 5, 2017.
Facts
- On October 26, 1955, Cadastral Decree No. N-31626 was issued to Valentina Espinosa covering a 28,880-sqm lot in Sipalay City, Negros Occidental (Lot No. 3599, Cadastral Record No. 980).
- Original Certificate of Title (OCT) No. 191-N was issued to Espinosa on October 15, 1962.
- Espinosa sold the property to Leonila B. Caliston on June 17, 1976; Transfer Certificate of Title (TCT) No. T-91117 was issued on June 29, 1976.
- On January 13, 2003, the State (DENR Region VI, through the Office of the Solicitor General) filed a Complaint for annulment of title and/or reversion, alleging the land formed part of timberland as shown in LC Map No. 2978 certified January 17, 1986.
Intervention by Spouses Escarda
- Spouses Dioscoro and Estrella Escarda intervened, claiming occupancy since 1976 under the belief the land belonged to the State.
- They prayed for a restraining order against Caliston’s attempts to eject them.
- Caliston countered that the property was alienable land, invoked laches and prescription, and questioned the capacity of the intervenors to join a reversion suit.
RTC Decision (May 12, 2004)
- Declared OCT No. 191-N and TCT No. T-91117 null and void ab initio.
- Ordered surrender and cancellation of titles and reversion of the land to the