Case Summary (G.R. No. 175760)
Background of the Case
On December 9, 1999, Sogod Development Corporation filed an application for the judicial confirmation of title over Lot No. 2533 with an area of approximately 23,896 square meters. The Respondent claimed ownership of this land, asserting that it had been in open, continuous, exclusive, and notorious possession since June 12, 1945. The application was contested by the Office of the Solicitor General, which argued that the land was not alienable and disposable until January 17, 1986, and consequently, Sogod was disqualified from claiming title under Article XII, Section 3 of the 1987 Constitution.
Court Proceedings
The Municipal Circuit Trial Court of Catmon-Carmen-Sogod, Cebu, rendered a Decision on May 10, 2001, granting Sogod's application for registration. This decision was later affirmed by the Court of Appeals, which concluded that Sogod had sufficiently proven its continuous possession of the land since the required date. The Office of the Solicitor General subsequently filed an appeal, arguing several points of error related to the sufficiency of evidence and the nature of the land.
Legal Issues Raised
The primary legal issues presented to the Supreme Court included whether prior possession of forest land could count towards the required period for judicial confirmation of title and whether Sogod and its predecessors had possessed the property in the required manner since June 12, 1945. The Petitioner contended that any possession before the land's classification as alienable was legally irrelevant. Moreover, it also questioned Sogod's evidence of possession, particularly the timing of tax declarations and the validity of documents proving ownership.
Court's Findings on Possession and Ownership
The Supreme Court reiterated that Section 48(b) of Commonwealth Act No. 141 requires that applicants demonstrate open, continuous, exclusive, and notorious possession of alienable and disposable lands under a bona fide claim since June 12, 1945. The Court clarified that the classification of land as alienable and disposable only needed to occur by the time of the registration application, not retroactively to the period of possession.
The Court emphasized that possession could be established through a chain of ownership evidenced by tax declarations and testimonies, including the uninterrupted possession since 1945 and the cultivation of the land. Despite the Petitioner’s challenges regarding the
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Case Overview
- The case revolves around a Petition for Review on Certiorari (G.R. No. 175760) filed by the Republic of the Philippines against Sogod Development Corporation.
- The Supreme Court's decision, rendered on February 17, 2016, seeks to annul and set aside the earlier decisions of the Court of Appeals Cebu City, which affirmed the Municipal Circuit Trial Court's ruling granting Sogod's application for original registration of title over a specific parcel of land.
Background of the Case
- Sogod Development Corporation filed an application for registration and confirmation of land title over Lot No. 2533, Cad. 827-D, measuring 23,896 square meters in Brgy. Tabunok, Sogod, Cebu, on December 9, 1999.
- The corporation claimed ownership through a deed of absolute sale from Catalina Rivera dated October 28, 1996, and asserted that it, along with its predecessors-in-interest, had occupied the land continuously since June 12, 1945.
Legal Framework
- The application for judicial confirmation of title is governed by Section 48(b) of the Public Land Act, which requires the land to be alienable and disposable at the time of application, with possession dating back to June 12, 1945, or earlier.
- The Office of the Solicitor General opposed the application, citing disqualification under Article XII, Section 3 of the 1987 Constitution, which restricts private corporations from applying for original registration of public lands.
Proceedings in Lower Courts
- The trial court issued a general default order in favor of Sogod, and the Office of the Solici