Case Summary (G.R. No. 210738)
Relevant Antecedents
Spouses Alonso filed a petition for the registration of the subject land, claiming it as alienable and disposable public land, previously owned by spouses Rafael C. Montalvo and Manuel a Garnica since 1945. Following the latter's death, their heirs executed an Extrajudicial Settlement Among Heirs and sold the property to spouses Alonso through a Deed of Sale dated January 27, 1998. Spouses Alonso asserted they possessed the property in an open, continuous, exclusive, and notorious manner since time immemorial.
Initial Court Ruling
The Regional Trial Court (RTC) of Iloilo City, Branch 22, dismissed the petition on December 29, 2009, finding that spouses Alonso did not provide sufficient evidence to establish that their possession or that of their predecessors had met legal standards since 1945. After a Motion for Reconsideration was denied, spouses Alonso appealed to the Court of Appeals (CA).
Court of Appeals Decision
In its decision dated May 31, 2013, the CA reversed the RTC's dismissal, granting the registration of the subject land. The CA determined that the requirements for possession had been satisfied and ordered a decree of registration in favor of spouses Alonso.
Petitioner's Arguments
The Republic, through the OSG, appealed to the Supreme Court, asserting that spouses Alonso failed to prove their entitlement to register the land, specifically contesting their evidence regarding alienability and disposability.
Key Legal Issue
The primary legal issue addressed is whether the registration of the subject land was appropriate under existing laws and regulations governing land registration and classification.
Relevant Laws and Requirements
The decision referenced Presidential Decree No. 1529, which sets forth the criteria for land registration applications, particularly focusing on the requirement for applicants to demonstrate open, continuous, exclusive, and notorious possession of alienable and disposable lands since June 12, 1945, or earlier, alongside proof of the land's classification status as disposable.
Evidence of Alienability
The Court noted that showing a land's status as alienable and disposable requires documentation from official government bodies, specifically the Community Environment and Natural Resources Office (CENRO) or the Department of Environment and Natural Resources (DENR). This evidence is vital to validly establish the nature of the land in question.
Absence of Critical Documentation
The Supreme Court concluded that spouses Alonso did not present necessary documentation, such as certifications from CENRO or PENRO that would classify the land as alienable and disposable. The relianc
...continue readingCase Syllabus (G.R. No. 210738)
Overview of the Case
- This case involves a Petition for Review on Certiorari filed by the Republic of the Philippines, represented by the Office of the Solicitor General (OSG), contesting the Decision dated May 31, 2013, and the Resolution dated December 12, 2013, of the Court of Appeals-Cebu City.
- The core issue is the registration of Lot 2209, Cad. 24, Iloilo Cadastre, AP-06-005399, claimed by spouses Guillermo Alonso and Inocencia Britanico-Alonso (spouses Alonso).
Facts of the Case
- The spouses Alonso filed a petition for the registration of the subject land, asserting that it is an alienable and disposable public land previously owned by spouses Rafael C. Montalvo and Manuel a Garnica (spouses Montalvo).
- They claimed that following the death of the spouses Montalvo, their heirs executed an Extrajudicial Settlement Among Heirs with Waiver of Hereditary Shares and sold the land to the spouses Alonso via a Deed of Sale dated January 27, 1998.
- The spouses Alonso contended that they, along with their predecessors-in-interest, had been in open, continuous, exclusive, and notorious possession of the land since time immemorial.
Proceedings in Lower Courts
- The Regional Trial Court (RTC) of Iloilo City, Branch 22 dismissed the petition on December 29, 2009, due to the spouses Alonso's failure to prove their continuous and notorious possession since time immemorial or prior to 1945.
- The spouses Alonso's Motion for Reconsideration was denied on April 26, 2010, prom