Case Summary (G.R. No. L-48738)
Applicable Law
The applicable legal framework for this case includes provisions under the 1987 Philippine Constitution, the Property Registration Decree (Presidential Decree No. 1529), the Public Land Act (Commonwealth Act No. 141), as well as Republic Act No. 4850 governing public lands.
Factual Background
On December 3, 2001, Remman Enterprises, Inc. applied for judicial confirmation of title over two parcels of land in Taguig, Metro Manila, totaling approximately 50,302 square meters. The RTC subsequently set hearings to determine the application's validity, leading to oppositions filed by the Laguna Lake Development Authority (LLDA) and the Republic of the Philippines, both asserting that the lands in question did not qualify as alienable and disposable public lands.
Evidence Presented
Throughout the judicial process, both parties presented evidence and witness testimony to support their claims. The Respondent argued it had possessed the subject properties since 1943 through a series of transfers, asserting that these lands were within the alienable and disposable domains of public lands as certified by the Department of Environment and Natural Resources (DENR). The LLDA, in opposition, presented expert testimony indicating that the land elevations fell below the necessary threshold to be classified as alienable land.
RTC Findings
On May 16, 2007, the RTC ruled in favor of Remman Enterprises, concluding that the company had proven the subject properties were not part of the bed of Laguna Lake and that it and its predecessors-in-interest had been in continuous possession of the land since before 1945, thus granting the registration of title.
CA Ruling
The Court of Appeals affirmed the RTC decision on November 10, 2011, agreeing that the Respondent had demonstrated the alienable status of the land through sufficient evidence, and rejecting the opposing claims of the Petitioner while criticizing the evidentiary support for LLDA's position.
Legal Issues
The central issue before the Supreme Court was whether the lower courts erred in affirming the RTC's decision and granting the application for registration of title. The Petitioner contended that the elevations of the properties fell below the legal threshold and therefore constituted part of the bed of Laguna Lake, which would preclude alienability.
Court's Ruling
The Supreme Court granted the petition, determining that while the lower courts' findings on elevation might not be disregarded, the Respondent ultimately failed to satisfy the burden of proof necessary to classify the land as alienable and disposable. The Court emphasiz
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Case Overview
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to annul the Decision of the Court of Appeals dated November 10, 2011, which affirmed the Decision of the Regional Trial Court (RTC) of Pasig City dated May 16, 2007.
- The RTC had granted the application of Remman Enterprises, Inc. (respondent) for judicial confirmation of title over two parcels of land in Barangay Napindan, Taguig, Metro Manila.
Facts of the Case
- On December 3, 2001, Remman Enterprises, Inc. filed an application with the RTC for judicial confirmation of title over two parcels of land, Lot Nos. 3068 (29,945 sq m) and 3077 (20,357 sq m).
- The RTC found the application sufficient and set an initial hearing, later published in the Official Gazette and a newspaper.
- At the initial hearing on May 30, 2002, only the Laguna Lake Development Authority (LLDA) appeared to oppose the application, leading to a general default ruling against other parties.
- The LLDA and the Republic of the Philippines filed oppositions, claiming the lands were not alienable and disposable and that possession was not sufficiently proven.
- The RTC trial included testimonies from four witnesses for the respondent and two for the LLDA, regarding the ownership and characteristics of the land in question.
Trial Evidence Presented
- Respondent's witnesses included Teresita Villaroya, Ronnie Inocencio, Cenon Cerquena (caretaker since 1957), and Engineer Mariano Flotildes (geodetic engineer).
- The LLDA's witnesses were Engineers Ramon Magalonga and Christopher Pedrezuela.
- The respondent claimed continuous, exclusive possession of