Case Summary (G.R. No. 183063)
Legal Proceedings
Cayetano L. Serrano filed an application for registration of the land on September 21, 1988, claiming ownership by inheritance from his deceased parents and based on a Deed of Exchange, alongside a private deed of partition that he forged with his co-heirs. He asserted open, continuous, exclusive, and notorious possession of the land since before 1917. The heirs of Catalino M. Alaan intervened by filing their own application for registration in connection with their purchase of a portion of the lot from Cayetano in 1989, to which Cayetano did not object.
Trial Evidence
At trial, various documents were presented to support Cayetano's claim, including tax declarations, official receipts for real estate tax payments, and a survey plan. Cayetano's brother, Leonardo Serrano, testified about the family's history with the lot, detailing ownership transfer from earlier owners to their parents and the subsequent occupation of the land.
Court Decisions
On November 3, 2003, the Regional Trial Court granted the applications for registration, which was later affirmed by the Court of Appeals on May 13, 2008. The appellate court noted that there was sufficient evidence to prove that the land was classified as alienable and disposable, fulfilling the requirements of the Property Registration Decree.
Legal Standards for Land Registration
Under Section 14(1) of the Property Registration Decree, for an application to be granted, it must be established that the property is alienable and disposable, and that the applicant has been in open and continuous possession since June 12, 1945, or earlier. The court found that Cayetano and his predecessors met these criteria, marking the fulfillment of necessary legal requisites for registration.
Possession and Claim of Ownership
The decision emphasized that while tax declarations are not conclusive evidence of ownership, they do indicate possession
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Background of the Case
- Respondent Cayetano L. Serrano filed an application for registration of a 533-square meter parcel of land known as Lot 249, located in Poblacion Cabadbaran, Agusan del Norte, on September 21, 1988.
- Cayetano claimed ownership of the lot through inheritance from his deceased parents, Simeon Serrano and Agustina Luz, a Deed of Exchange dated February 10, 1961, and a private deed of partition and extrajudicial settlement.
- Cayetano asserted that he and his predecessors had been in open, continuous, exclusive, and notorious possession of the property for over 70 years.
Intervenor's Claim
- The Heirs of Catalino M. Alaan, represented by Paulita P. Alaan, intervened in the case, claiming a 217.45-square meter portion of the lot purchased from Cayetano on February 27, 1989.
- They requested that their application for confirmation of title be considered alongside Cayetano's, and sought joint issuance of original certificates of title.
Proceedings and Evidence Presented
- During the trial, Cayetano was represented by his brother, Leonardo Serrano, due to his passing during the proceedings.
- Cayetano's evidence included various documents: a survey plan from 1957 certified by the DENR, tax declarations from 1924 to 1997, and receipts for real estate tax payments.
- Leonardo testified via wr