Case Summary (G.R. No. 164408)
Applicable Law
The foundational legal framework for this case is Presidential Decree (PD) No. 1529, which governs the registration of land in the Philippines, particularly as it pertains to public domain lands and the requirements for securing private ownership through registration.
Procedural Background
On May 28, 1993, the respondent filed an application for original registration of the land, asserting ownership based on a purchase from Jane de Castro Abalos in 1992. The application was supported by various documents, including a tax declaration and a deed of sale. The Republic opposed the registration, claiming that there had not been sufficient proof of the required length of possession and that the land constituted public domain ineligible for private appropriation.
Initial Findings by the Regional Trial Court
The Regional Trial Court (RTC) in San Pedro, Laguna, supervised the proceedings and requested status reports from relevant government agencies regarding the land’s classification and any existing claims. A comprehensive report confirmed that the land was verified as alienable and disposable and that there were no adverse claims. The RTC ruled in favor of the respondent on May 12, 1997, granting the application based on established possession since prior to 1960.
Appeal and Court of Appeals Judgment
The Republic appealed the RTC's decision, contending that the evidence presented did not substantiate that the respondent and its predecessors possessed the land for the required period. On June 10, 2004, the Court of Appeals upheld the RTC's finding, stating that the evidence supported claims of long-term possession under a bona fide ownership assertion.
Legal Issues Raised
The Republic argued that the Court of Appeals had erred in affirming the registration since there was a lack of evidence indicating when the land had been classified as alienable and disposable. Under P.D. No. 1529, the acquisition through possession only applies if such a declaration had occurred prior to or during the period of claimed possession.
Respondent's Position
The respondent contended that the question of the land's classification was waived as it was not raised in the initial proceedings. They maintained that their long-standing possession, with the land declared for taxation purposes since 1960, constituted adequate grounds for ownership transfer.
Court's Ruling
The Supreme Court granted the petition for review, highlighting that registration under Section 14(2) of PD No. 1529 requires the land to have been recognized as patrimonial pr
...continue readingCase Syllabus (G.R. No. 164408)
Case Citation
- 730 Phil. 263
- G.R. No. 164408, March 24, 2014
Parties Involved
- Petitioner: Republic of the Philippines
- Respondent: Zurbaran Realty and Development Corporation
Background of the Case
- On May 28, 1993, Zurbaran Realty and Development Corporation filed for original land registration for a 1,520 square meter parcel of land in Barrio Banlic, Cabuyao, Laguna.
- The land was claimed to have been purchased from Jane de Castro Abalos on March 9, 1992, for P300,000.
- The application included various documents such as tax declarations and a deed of sale, asserting continuous and exclusive possession of the land.
- The Republic, represented by the Director of Lands, opposed the application, contending that the land was still part of the public domain and that the required possession period had not been met.
Proceedings in the Regional Trial Court (RTC)
- The RTC instructed relevant government offices to submit reports on the land's status.
- CENRO confirmed that the land was classified as alienable and disposable and that there were no adverse claims against it.
- Several witnesses, including company officials and individuals familiar with the land's history, testified in favor of the respondent's claim of ownership.
- On May 12, 1997, the RTC ruled in favor of the respondent, confirming the registration of the land under the name of Zurbaran Realty and Development Corporation.
Court of Appeals (CA) Judgment
- The Republic appealed the RTC's decision, questioning the determination of possession and the