Case Summary (G.R. No. 189970)
Background of the Case
Crisanto S. Raneses filed an application for original land title registration over two parcels of land designated as Lot No. 3085-A and Lot No. 3085-B, totaling 22,600 square meters, on March 26, 2007. The application was grounded on claims of continuous possession by his family dating back to 1945. The respondent indicated that his late father, Pedro Raneses, had cultivated the land for agricultural purposes until his passing, which ceased cultivation operations.
Proceedings at the Regional Trial Court
During the initial hearing on September 24, 2007, the RTC, finding no opposing claims, issued an Order of General Default, allowing respondent to present evidence ex parte. Notably, testimony was provided indicating that while tax declarations for the properties began in 1980, the family had occupied the land without interruption since at least 1945. This included claims of agricultural use and the execution of an Extrajudicial Settlement of Estate, which transferred ownership rights to Crisanto Raneses.
Opposition from the Laguna Lake Development Authority
Following the RTC's granting of the application on October 11, 2007, the Laguna Lake Development Authority (LLDA) opposed the application. LLDA contended that the lands in question were below the critical elevation of 12.50 meters and thus classified as beds of Laguna Lake, rendering them inalienable and non-disposable. An official memorandum from LLDA supported this claim, contradicting the findings from the respondent’s submitted reports.
RTC's Dismissal of Opposition
Respondent subsequently filed a comment and motion urging the RTC to disregard LLDA's opposition based on alleged procedural deficiencies in its submission. On November 27, 2007, the RTC upheld the respondent's arguments, dismissing LLDA's opposition, which prompted the LLDA to appeal the decision.
Court of Appeals' Judgment
The Court of Appeals affirmed the RTC's decisions on June 18, 2009, holding that the respondent demonstrated sufficient evidence to show that the properties were indeed part of the alienable and disposable lands of the public domain. The appellate court’s findings emphasized reliance on the Inter-Office Memorandum from LLDA over the concerns raised by LLDA's later memorandum.
Petitioner’s Grounds for Review
The petitioner challenged the CA's decision, arguing that the subject lands remain inalienable given their classification under public land laws and raised the necessity for incontrovertible evidence proving their alienable status, alleging that the respondent failed to present the required documentation for land classification.
Legal Framework
The relevant legal provisions include Section 14(1) of Presidential Decree No. 1529 and provisions from Commonwealth Act No. 141 which govern applications for registration of land titles, emphasizing conditions pertaining to possession of alienable and disposable lands of the public domain. The Regalian Doctrine under Article XII, Section 2 of the 1987 Constitution esta
...continue readingCase Syllabus (G.R. No. 189970)
Case Background
- The case is a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, seeking to reverse the Decision dated June 18, 2009, of the Court of Appeals (CA).
- The CA had affirmed Orders dated October 11, 2007, and November 27, 2007, from the Regional Trial Court (RTC) of Pasig City regarding Land Registration Case No. N-11573-TG.
- Respondent Crisanto S. Raneses applied for original registration of land title for two parcels of land in Barangay Napindan, Taguig City, totaling 22,600 square meters.
Factual Background of the Case
- On March 26, 2007, Raneses filed an application for land registration, marking several documents to satisfy jurisdictional requirements.
- The RTC issued an Order of General Default against all parties except the Republic of the Philippines and allowed Raneses to present evidence ex parte.
- Raneses testified about his family's continuous possession of the land since June 1945, detailing agricultural use and tax declarations since 1980.
- An Extrajudicial Settlement of Estate was executed in 1997, transferring ownership to Raneses.
- The properties were surveyed and noted as alienable and disposable land by a private Geodetic Engineer.
Testimonies and Evidence Presented
- Raneses and his mother testified about the family's long-term possession and use of the land, including agricultural activities.
- They presented an Inter-Office Memorandum from the Laguna Lake Development Authority (LLDA), affirming the properties' elevation above the reglementary 12.5