Republic Of The Philippines v. Tri-Plus Corporation
Republic of the Philippines v. Tri-Plus Corporation, G.R. No. 150000, September 26, 2006
- Procedural (Remedial Law)
- Civil Law
- confirmation of imperfect title
- public domain
- alienable and disposable land
- open, continuous, exclusive and notorious possession
- June 12, 1945
- regalian doctrine
- Torrens system
- burden of proof
- jurisdiction and appeal
- LRA report
- Rule 45
I. Facts of the Case
Tri-Plus Corporation applied for registration of title over Lots 1061 and 1062 of the Cadastral Survey of Consolacion, Cebu, claiming ownership and possession in the concept of an owner for more than 30 years. The Republic opposed, arguing that the land had not been proven alienable and disposable public land and that Tri-Plus and its predecessors-in-interest failed to prove the required possession since June 12, 1945 or earlier. The MTC granted the application and the CA affirmed, but the Supreme Court ultimately dismissed the application for failure to meet the legal requisites for confirmation of imperfect title.
1997-04-30
Tri-Plus Corporation, through its president Euclid C. Po, filed with the MTC of Consolacion, Metro Cebu an Application for Registration of Title over Lots 1061 and 1062, alleging acquisition by purchase and possession in the concept of an owner for more than 30 years.
1997-09-04
The Republic of the Philippines, through the OSG, filed an Opposition asserting that Tri-Plus and its predecessors-in-interest were not in open, continuous, exclusive, and notorious possession since June 12, 1945 or prior; that the submitted muniments (e.g., tax declarations and receipts) were not competent proof of bona fide acquisition and the required possession; that the Spanish claim was no longer available due to failure to file under P.D. No. 892; and that the parcels remained portions of the inalienable public domain.
1997-09-19
Tri-Plus presented documentary evidence to establish compliance with the jurisdictional requirements. On the same date, the heirs of Toribio Pepito sought a 10-day extension to file written opposition, but they failed to file their opposition on time; the trial court commissioned its clerk to receive evidence and submit a report.
1998-02-26
The MTC rendered judgment granting Tri-Plus’s application, finding from the totality of the evidence that Tri-Plus and its predecessors-in-interest had actual, public, exclusive, and continuous possession in the concept of an owner for at least 30 years prior to the application, and ordered confirmation under the Torrens System with issuance of the decree once the judgment became final.
1997-12-??
The OSG appealed the MTC judgment to the Court of Appeals; during the appellate proceedings, the LRA (via its Director on Registration) submitted an August 6, 1998 Report noting discrepancies in bearings and distances of a line segment of Lot 1061 compared with another plan.
2001-09-14
The Court of Appeals affirmed the MTC decision, finding no reversible error.
2006-09-26
The Supreme Court granted the Republic’s petition, reversed the CA and MTC rulings, and dismissed Tri-Plus’s application for registration for failure to prove (a) that the parcels were alienable and disposable agricultural lands of the public domain, and (b) the required open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945 or earlier.
II. Issues
Whether or not the trial court lost jurisdiction to hear and decide the case due to the submission of a report by the LRA after the MTC decision and after the appeal was perfected.
Whether or not Tri-Plus failed to discharge the burden of proving that the property is alienable and disposable agricultural land of the public domain.
Whether or not Tri-Plus is disqualified from acquiring lands of the public domain for failure to prove the required possession under a bona fide claim of ownership since June 12, 1945 or earlier.
III. Ruling
Whether or not the trial court lost jurisdiction to hear and decide the case due to the submission of a report by the LRA after the MTC decision and after the appeal was perfected.
The LRA’s report did not divest the trial court of jurisdiction because it was submitted after the MTC decision and after the appeal had been perfected, vesting jurisdiction in the appellate court.
How the Court reasoned
- The Court recognized that the LRA report was submitted after the MTC rendered its decision and after the appeal was perfected, meaning the appellate court had already acquired jurisdiction.
- Because the report came after the MTC’s ruling, it could not retroactively affect the MTC’s jurisdiction at the time it decided the case.
- While the existence of discrepancies noted in the LRA report was relevant to the identity and description of the land, the jurisdictional complaint based solely on the timing of the report was not a proper basis to nullify the MTC proceedings.
“The MTC could not have possibly done this because said Report was submitted to the trial court more than five months after the latter rendered its Decision.”
Rule applied
Rule 45 of the Rules of Court; general rule that jurisdiction over the case shifts to the appellate court upon perfection of appeal
Whether or not Tri-Plus failed to discharge the burden of proving that the property is alienable and disposable agricultural land of the public domain.
Tri-Plus failed to prove by clear and convincing evidence that the subject lands were alienable and disposable agricultural lands of the public domain.
How the Court reasoned
- Applicants for confirmation of imperfect title must prove that the land sought to be titled is part of the alienable and disposable agricultural lands of the public domain.
- The Court found that respondent did not present sufficient and competent proof showing the alienable and disposable character of the parcels, including proof of the proper date when the lands became so.
- The Court thus agreed with the Republic that there was no basis to conclude that the parcels had already become private property.
“In the present case, the Court finds that respondent failed to prove, by clear and convincing evidence, the legal requirements that the lands sought to be titled are alienable and disposable and that its predecessors-in-interest were already in possession of the subject lots since 1945 or earlier.”
Rule applied
Commonwealth Act No. 141, as amended; Regalian doctrine; requirements for confirmation of imperfect title under Batas Pambansa Blg. 129, as amended by R.A. No. 7691; relevant land registration jurisprudence requiring proof of alienable and disposable character
Whether or not Tri-Plus is disqualified from acquiring lands of the public domain for failure to prove the required possession under a bona fide claim of ownership since June 12, 1945 or earlier.
Tri-Plus also failed to prove the required open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945 or earlier, so it could not obtain confirmation of title over inalienable public land.
How the Court reasoned
- The Court reiterated the requisites for confirmation: (a) alienable and disposable status, and (b) open, continuous, exclusive, and notorious possession under a bona fide claim either since time immemorial or since June 12, 1945.
- The evidence presented by respondent, including documents such as tax declarations and receipts and other submissions, did not meet the standard of proof required to establish the required possession and the bona fide claim since the legally relevant date.
- Because respondent failed to satisfy both the alienable-and-disposable requirement and the required possession starting point, the parcels remained part of the inalienable public domain and could not be the subject of confirmation of imperfect title.
Rule applied
Commonwealth Act No. 141, as amended; Commonwealth Act No. 141’s regalian doctrine; P.D. No. 892 (on disposition/confirmation framework as raised by the parties); jurisprudence on confirmation of imperfect title requiring possession since time immemorial or since June 12, 1945
Doctrines
Applicants for confirmation of imperfect title must prove (a) that the land forms part of the alienable and disposable agricultural lands of the public domain, and (b) that they have been in open, continuous, exclusive and notorious possession and occupation of the same under a bona fide claim of ownership either since time immemorial or since June 12, 1945.
Under the Regalian doctrine, lands of the public domain are presumed to belong to the State and cannot be the subject of private ownership or confirmation of imperfect title unless the applicant establishes by clear and convincing evidence that the land has already become alienable and disposable and that the possession requirements are strictly complied with.
Final Disposition
WHEREFORE, the petition is GRANTED. The assailed Decision dated September 14, 2001 of the Court of Appeals in CA-G.R. CV No. 60671 is REVERSED and SET ASIDE. The application for registration of title filed by Tri-Plus Corporation over Lots Nos. 1061 and 1062 is DISMISSED for failure to prove that the properties are alienable and disposable public lands and that the required possession under a bona fide claim of ownership existed since June 12, 1945 or earlier. Costs against respondent.
Notes
The Supreme Court treated the timing of the LRA report as a jurisdictional point that did not affect the MTC’s authority since the report was submitted after the MTC decision and after perfection of the appeal; however, the decisive ground for reversal was respondent’s failure of proof on (1) alienable and disposable status and (2) the required possession from the legally relevant date.