Case Summary (G.R. No. 185603)
Petitioner’s Arguments
The Republic of the Philippines, through the Office of the Solicitor General, opposed the application for land registration filed by the respondent. It contended that neither the respondent nor its predecessors had established the requisite period of open, continuous, exclusive, and notorious possession for at least thirty years. The petitioner also argued that the tax declarations submitted as evidence did not substantiate ownership and emphasized that the application could not be granted since the land was part of the public domain and had not been classified as alienable until 1982.
Trial Court's Findings
The trial court initially ruled in favor of the respondent, citing that possession of the subject property had been established back to 1948 through its predecessors, Andres Velando and Juana Velando. The court concluded that the evidence, including tax records starting from 1948 and testimonies confirming possession and improvements to the property, substantiated a continuous ownership claim spanning fifty-seven years.
Court of Appeals' Ruling
The Court of Appeals upheld the trial court’s decision, emphasizing the sufficiency of the period of possession dating back to 1943. The Court noted that the state’s classification of the land as alienable and disposable before the application was filed meant that the land no longer fell under public domain. The CA found no merit in the petitioner’s claim that the possession should only be reckoned from the date of the land's classification as alienable.
Issues Presented
The primary legal challenge presented was whether the period of possession claimed by the respondent was sufficient to warrant the registration of title in light of the legal requirements stipulated by the Property Registration Decree (P.D. No. 1529), specifically the stipulated effective date of possession before the declaration of the land’s alienable status.
Supreme Court's Ruling
In its ruling, the Supreme Court reiterated that compliance with Section 14(1) of P.D. No. 1529 merely requires that the land is classified as alienable and disposable at the time of application for registration, not necessarily prior to th
...continue readingCase Syllabus (G.R. No. 185603)
Jurisdiction and Background
- This case is a petition for review on certiorari filed under Rule 45 of the Rules of Court by the Republic of the Philippines (petitioner) aimed at reversing the Decision dated December 4, 2008, of the Court of Appeals (CA).
- The CA's ruling affirmed the decision dated March 9, 2007, of the 2nd Municipal Circuit Trial Court of Silang-Amadeo, Silang, Cavite, in the application for land registration identified as LRC No. 2006-324.
Facts of the Case
- The applicant, a religious institution, claims to have acquired the property in question through a Deed of Sale dated September 19, 2005.
- The applicant asserts continuous, uninterrupted, open, and public possession of the property since the acquisition, with predecessors-in-interest having similar possession dating back to 1940, totaling over fifty years.
- The complaint contained details about adjoining lot owners as mandated by the Rules, and the trial court set a hearing for the registration application.
- The petitioner, represented by the Office of the Solicitor General, opposed the application, arguing:
- Lack of sufficient possession by the applicant or its predecessors for at least thirty years.
- Tax declarations submitted as evidence were of recent origin and inadequate as title muniments.
- The applicant failed to file for registration within six months of the land's declaration as alienable and disposable.
- The land in question was part of the public domain and thus not subject to appropriation.