G.R. No. 177790 - Republic vs. Vega

Case Summary (G.R. No. 177790)

Procedural History and Application for Registration

Respondents Vegas initiated Land Registration Case No. 103-95-C before the Regional Trial Court (RTC), Branch 92, Calamba, Laguna, seeking registration of title to the subject property. The Republic opposed, claiming the land was public domain and thus inalienable. Respondents-intervenors Buhays claimed a portion of the land based on a prior purported sale from respondents Vegas' mother to their predecessors-in-interest. The RTC granted the registration application, ordering issuance of titles in favor of respondents Vegas and respondents-intervenors Buhays. The Court of Appeals (CA) affirmed this decision. The Republic filed a Rule 45 Petition for certiorari contesting the CA ruling.

Issues on Procedural Defects Raised by Respondents

Respondents argued that the petition filed by the Republic suffered from procedural defects:
(a) Failure to attach essential portions of the record, specifically the appellee’s brief, allegedly violating Rule 45, Section 4(d) of the Rules of Court; and
(b) The petition raised questions of fact, which are beyond the proper scope of a Rule 45 petition that involves questions of law.

The Supreme Court held that the failure to attach the appellee’s brief is not fatal and may be left to the discretion of the petitioner. It further clarified that the petition raises a question of law, specifically whether the evidence presented suffices to support the classification of land as alienable and disposable, making it properly cognizable under Rule 45.

Applicable Law on Original Registration of Lands

Presidential Decree No. 1529, the Property Registration Decree, section 14, provides that only those who have been in open, continuous, exclusive, and notorious possession of alienable and disposable lands of the public domain under bona fide claims of ownership since June 12, 1945, or earlier, may file for original registration. The requisites for registration include:
(1) Proof that the subject land is alienable and disposable public land; and
(2) Proof of possession as stated above.

The primary legal issue is whether respondents sufficiently established that the land was alienable and disposable, as occupation alone does not confer ownership over inalienable public lands.

Proof Required to Establish That Land Is Alienable and Disposable

Land classification or reclassification requires positive proof. Applicants must establish a positive government act, such as:

Presidential Proclamation or Executive Order;
Administrative Acts;
Investigation reports from Bureau of Lands or DENR officials; or
Legislative acts or statutes.

A certification from governmental authorities, specifically the Department of Environment and Natural Resources (DENR), indicating alienable and disposable status is generally essential. Prior jurisprudence allowed CENRO (Community Environment and Natural Resources Office) certifications to suffice, giving them presumption of regularity.

However, in Republic v. T.A.N. Properties, Inc., the Court clarified that a CENRO or PENRO certification alone is insufficient. Applicants must also present a certified true copy of the DENR Secretary-approved original classification with verification from DENR offices, establishing both the classification and governmental release of the land as alienable and disposable.

Substantial Compliance Doctrine and Application in this Case

Respondents Vegas did not produce the stringent documentation mandated by Republic v. T.A.N. Properties, Inc., namely the CENRO certification together with a certified true copy of the original DENR Secretary classification. Strict application of this requirement would warrant denial of their registration claim.

Nonetheless, because the RTC and CA decisions predated the T.A.N. Properties ruling, the Court of Appeals applied the doctrine of substantial compliance, which was recently affirmed in Republic v. Serrano. Under this doctrine, a DENR Regional Technical Director’s certification annotated on a subdivision plan was deemed substantial compliance with the alienable and disposable land requirement. The certification enjoys a presumption of regularity absent evidence to the contrary, especially when no substantive opposition is filed by the DENR or Land Registration Authority (LRA).

Evidence Supporting Alienable and Disposable Classification

(1) Testimony of Mr. Rodolfo Gonzales, CENRO Special Investigator: He attested after inspection that the subject area was within an alienable and disposable zone per Project No. 15, L.C. Map No. 582, certified December 31, 1925. His report confirmed no forfeiture, no prior patent or registration, and no public land applications conflicting with the area.
(2) Subdivision Plan Csd-04-024336-D, submitted by respondents-intervenors Buhays, was annotated by Mr. Samson G. de Leon, DENR Officer-in-Charge, affirming the land’s status as alienable and disposable as per the same 1925 map.
(3) The LRA did not challenge the alienable and disposable character of the land at trial but only recommended dismissal of a separate, duplicate application, indicating tacit acceptance of respondents’ claims.
(4) The OSG’s opposition was pro forma, and the Republic failed to cross-examine the witness or produce contradictory evidence.

On the Absence of Testimony as to the Date of Classification

Petitioner Republic criticized Mr. Gonzales’ failure to specify in court the exact date when the land was declared alienable and disposable or when the investigation was conducted. The Court held that this deficiency could have been explored through cross-examination, which the Republic waived by repeated absences and failure to present evidence. The report itself clearly indicated the classification date as December 31, 1925, providing satisfactory evidence.

Court’s Ruling and Legal Principles Affirmed

The Supreme Court affirmed the decisions of the RT

Case Syllabus (G.R. No. 177790)

Case Background and Parties Involved

Petition filed by the Republic of the Philippines (petitioner), through the Office of the Solicitor General (OSG), under Rule 45 questioning the Court of Appeals decision.
Respondents are Carlos R. Vega, Marcos R. Vega, Rogelio R. Vega, Lubin R. Vega, and the heirs of Gloria R. Vega; respondents-intervenors are the Buhay family members.
Subject of the case: original registration application for title over Lot No. 6191, Cadastre 450 of Los Baños, Laguna, covering 6,902 square meters.
Respondents Vegas claim inheritance of the land from their mother, who inherited it from their grandfather; petitioner Republic contests this claiming the land is public domain and not subject to private ownership.

Procedural History

Respondents Vegas filed application for registration on May 26, 1995; case docketed as Land Registration Case No. 103-95-C before Regional Trial Court of Calamba, Laguna.
Petitioner's opposition filed on June 21, 1995, arguing subject land or parts thereof are public domain.
Respondents-intervenors Buhays claimed 826 square meters of the subject land, alleging they purchased it from respondents Vegas’ mother’s predecessors.
Trial court granted registration in favor of respondents Vegas and intervenors Buhays in November 2003.
Court of Appeals affirmed the trial court decision in 2007.
Petitioner Republic filed Rule 45 petition before the Supreme Court disputing the land classification.

Issues Raised and Respondents’ Procedural Objections

Respondents contended procedural deficiencies in the Petition:
- Failure to attach material portions of the record, namely respondents Vegas' Appellee's Brief.
- Alleged that petition raised factual questions beyond Rule 45 review.
Supreme Court held:
- Non-inclusion of the Appellee’s Brief is not a fatal defect.
- Rule 45 petitions may be filed based on questions of law, and this petition involves legal questions on sufficiency of evidence.
- The petition thus passes procedural requirements for consideration.

Applicable Law: Property Registration Decree (Presidential Decree No. 1529)

Section 14 provides who may apply for registration of title to land:
- Those who possess alienable and disposable public land under bona fide claim since June 12, 1945 or earlier.
Two requisites to prove for original registration:
1. The land is alienable and disposable public domain.
2. Applicant’s possession is open, continuous, exclusive, and notorious under bona fide claim since June 12, 1945 or earlier.
Focus of the case: sufficiency of evidence that subject land is alienable and disposable.

Proof of Alienable and Disposable Character of Land

Alienable and disposable land status requires positive government action:
- Presidential proclamation, executive order, legislative act, administrative action.
- Investigation reports by the Bureau of Lands or DENR.
- Certification from the government attesting to alienable and disposable status.
Previously, CENRO certification deemed suffi