Title
Supreme Court
Republic vs. Tri-Plus Corporation
Case
G.R. No. 150000
Decision Date
Sep 26, 2006
Tri-Plus Corp. sought land title registration for two lots in Cebu, claiming 30+ years of possession. The Supreme Court denied the application, ruling Tri-Plus failed to prove the land was alienable and disposable or that possession dated back to June 12, 1945, as required by law.

Case Summary (G.R. No. 150000)

Factual Background

Tri-Plus Corporation filed an application for registration of title over two parcels of land, identified as Lots 1061 and 1062 of the Cadastral Survey of Consolacion, Cebu, in the Municipal Trial Court of Consolacion. The corporation claimed ownership by virtue of purchase and asserted possession of the land for over thirty years, including that of its predecessors-in-interest.

Opposition to Application

The Republic of the Philippines, through the Office of the Solicitor General, opposed the application, arguing that neither Tri-Plus nor its predecessors had openly and continuously possessed the land since June 12, 1945. The government contended that the evidence presented, such as tax declarations, failed to demonstrate bona fide ownership and that the parcels remained public domain, unalienable by private individuals.

Trial Court Proceedings

Despite the opposition, the trial court ruled in favor of Tri-Plus, concluding that sufficient evidence demonstrated the applicant’s ownership and possession as claimed. The court ordered the issuance of a decree of registration for the lots once the decision became final. The Office of the Solicitor General subsequently appealed to the Court of Appeals.

Findings of the Court of Appeals

The Court of Appeals affirmed the trial court's ruling, holding there were no reversible errors in the decision. The appeals court found that the applicant had established sufficient evidence for the identity of the lands and the conditions required for registration.

Assignments of Error

In the Supreme Court, the Republic raised several points of error, asserting that:

  1. The identity of Lot 1061 was uncertain, undermining the trial court's jurisdiction.
  2. Tri-Plus did not meet the burden of proof to demonstrate that the lands were alienable and disposable.
  3. The respondent had failed to establish qualification for acquiring public domain lands.

Supreme Court Evaluation - Identity of the Land

The Supreme Court clarified that while originally submitting an approved land plan is mandatory, other forms of identification, such as a blueprint certified by the relevant government agency, are also acceptable. The Court concluded that the discrepancies in the property descriptions were not sufficient to cast doubt on the identity of Lot 1061 since they did not materially affect the area sought to be registered.

Supreme Court Evaluation - Alienability and Possession

The Court held that Tri-Plus failed to prove that the lands were classified as alienable and disposable, relying merely on notations from a survey plan rather than substantive governmental acts. The Court reiterated the requirement for positive acts, such as presidential proclamations, to evidence the land's classification.

Requirement of Possession

The testimonies presented by Tri-

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