Case Summary (G.R. No. 156205)
Background
The subject property in dispute stems from Land Registration Case No. 52, G.L.R.O. Record No. 3454, wherein the Court of First Instance of Batangas ruled on March 30, 1951, granting registration of several parcels of land to Hammon H. Buck et al. The origins of the subject land trace back to 1890, when it was owned by Rita Vda. de Ilustre. The property underwent several transfers before Buck registered it and received his Original Certificate of Title (OCT) No. 0-669.
Facts of the Case
In 1998, nearly five decades after the issuance of the OCT in Buck’s name, the DENR, acting on behalf of the Republic, sought annulment of the judgment that declared the property as private, the cancellation of the title, and reversion of the land to public domain. The DENR claimed the land covered by Transfer Certificate of Title (TCT) No. T-18592 was part of an unclassified public forest and therefore inalienable, challenging the legitimacy of the titles held by respondents Marjens and Villanueva.
Respondents’ Defense
Respondents contested the allegations, asserting their titles were valid and acquired under the Torrens system, arguing that the property was private long before the U.S. acquired sovereignty over the Philippines. They further asserted that the government, by its inaction, had lost the right to question the titles due to laches and estoppel since nearly fifty years had passed without challenge. The respondents also indicated that re-examination of the title would breach their due process rights due to the inability to present witnesses from the original trial.
Court of Appeals Decision
On November 19, 2002, the Court of Appeals dismissed the Republic’s petition, ruling in favor of the respondents. The court held that the property had ceased to be public land and had been appropriated to private ownership as early as 1890, based on historical precedents. It emphasized that the Court of First Instance possessed jurisdiction to adjudicate land registration, affirming the validity of Decree 6610, OCT No. 0-669, and TCT No. T-18592.
Judicial Rationale
The Court of Appeals invoked principles from the CariAko v. Insular Government of the Philippine Islands case, establishing that lands held under claim of ownership for significant periods should not be deemed public. The court noted that the government had inconsistently treated the land, having issued numerous Environmental Compliance Certificates (ECCs) in the area despite claiming the land was part of the public domain. Furthermore, it was highlighted that even if the land had subsequently been classified as part of an unclassified forest, prior private ownership rights needed recognition.
Government's Burden
The court corroborated that the government's position again
...continue readingCase Syllabus (G.R. No. 156205)
Background of the Case
- The Republic of the Philippines filed a petition for review on certiorari challenging the November 19, 2002 Decision of the Court of Appeals (CA-G.R. SP No. 50023).
- The CA dismissed the petition, asserting that the property in dispute had been classified as private and thus no longer part of the public domain.
- The case revolves around the property originally owned by Rita Vda. de Ilustre since 1890, which evolved through various transfers leading to its registration under Hammon H. Buck in 1952.
Facts of the Case
- On December 22, 1998, the petitioner filed a petition for annulment of judgment, cancellation of title, and reversion against Marjens Investment Corporation and Patrocinio Villanueva.
- The property in question is Lot 1 (LRC) Pcs-943, claimed by respondents under Transfer Certificate of Title (TCT) No. T-18592, issued in 1976.
- The Office of the Solicitor General (OSG) contended that the land was part of the unclassified public forest according to the Land Classification Control Map No. 10.
- Respondents countered that their titles were valid and claimed the government had lost rights due to laches and estoppel.
The Court of Appeals Decision
- The CA dismiss