Case Summary (G.R. No. 113578)
Background of the Application
SLDC filed an application for land registration on September 25, 1998, for two parcels of land: Lot No. 1, with an area of 74,488 square meters, and Lot No. 2, with an area of 529 square meters. The application was made under Presidential Decree No. 1529, asserting ownership through purchase in 1994 and 1995 and claiming open, continuous, exclusive, and notorious possession for over 30 years. SLDC provided nine witness testimonies and various documentary evidence, including certifications from governmental agencies confirming the parcels' status as alienable and disposable land.
Regional Trial Court (RTC) Ruling
The RTC granted SLDC's application on June 14, 2005, concluding that SLDC had established its claim of possession and occupation under Section 14(1) of P.D. No. 1529. The RTC confirmed the land's classification as alienable and disposable, directing the issuance of certificates of title post-decision finality.
Court of Appeals (CA) Ruling
Upon appeal, the Republic contested SLDC's claim of sufficient evidence for possession since June 12, 1945, as required under Section 14(1). The CA affirmed the RTC's grant but for different reasons, determining that SLDC had established its claim under Section 14(2), which allows registration based on possession through prescription. The CA found that SLDC's continuous possession for over 30 years entitled it to register the land despite not meeting the earlier date requirement.
Motion for Reconsideration
The Republic filed a motion for reconsideration, arguing that SLDC failed to demonstrate that the subject properties had been converted into private lands, a prerequisite under Section 14(2). The CA denied this motion, reiterating that SLDC’s long-term possession had effectively converted the land into private property open to prescription.
Arguments in the Supreme Court
The Republic petitioned to the Supreme Court, asserting that the CA erred in allowing SLDC's application under Section 14(2). The Republic maintained that SLDC did not adequately prove the land's conversion to private property or possessory requirements.
SLDC's Response
SLDC contended that it properly engaged Section 14(2) to substantiate its claim of ownership, emphasizing its lengthy possession and arguing that the Republic's failure to dispute alienability in prior appeals did not negate SLDC's evidence.
Supreme Court's Ruling
The Supreme Court emphasized that SLDC's claim relied on Section 14(2) and underscored the necessity for the
...continue readingCase Syllabus (G.R. No. 113578)
Case Background
- This case involves a Petition for Certiorari under Rule 45 of the Rules of Court.
- The petitioner is the Republic of the Philippines, and the respondent is San Lorenzo Development Corporation (SLDC).
- The petition assails the Decision dated July 31, 2014, and Resolution dated September 17, 2015, of the Court of Appeals - Cebu, which affirmed the Regional Trial Court's ruling in favor of SLDC regarding its land registration application.
Facts of the Case
- San Lorenzo Development Corporation is a corporation duly organized under Philippine laws, authorized to own lands.
- On September 25, 1998, SLDC filed an application for the registration of two parcels of land located in Barangay Buluang, Compostela, Cebu, under Presidential Decree No. 1529.
- The application claimed ownership through purchase in 1994 and 1995, asserting over 30 years of open, continuous, exclusive, and notorious possession.
- SLDC presented nine witnesses and various documentary evidence to support its claims, including:
- Approved tracing cloth plans and technical descriptions of the lots.
- Certifications regarding the status of the land as alienable and disposable.
- Deeds of Absolute Sale and tax declarations related to the properties.
RTC Ruling
- The Regional Trial Court granted SLDC's application, finding:
- SLDC esta