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Land Titles and Deed Case Digest

Casimiro Development Corporation v. Mateo


GR No. 175485, 27 July 2011

FACTS

In 1988, petitioner purchased from China Bank the land in question which was previously sold
by the mother of Mateo to Rodolfo Pe who in turn constituted a mortgage on the property in
favor of China Bank as security for a loan. China Bank foreclosed the mortgage and
consolidated its ownership of the property after Rodolfo failed to redeem. A TCT was issued in
the name of China Bank. In 1991, CDC brought an action for unlawful detainer against the
respondents siblings. Respondent counters that CDC acquired the property from China Bank in
bad faith because it had actual knowledge of the possession of the property by the respondent
and his siblings.

ISSUE

Whether CDC is an innocent purchaser for value.

HELD

RATIO

There is no doubt that the land in question, although once a part of the public domain, has
already been placed under the Torrens system of land registration. The Government is required
under the Torrens system of registration to issue an official certificate of title to attest to the fact
that the person named in the certificate is the owner of the property therein described, subject to
such liens and encumbrances as thereon noted or what the law warrants or reserves. The
objective is to obviate possible conflicts of title by giving the public the right to rely upon the face
of the Torrens certificate and to dispense, as a rule, with the necessity of inquiring further. The
Torrens system gives the registered owner complete peace of mind, in order that he will be
secured in his ownership as long as he has not voluntarily disposed of any right over the
covered land.

One who deals with property registered under the Torrens system need not go beyond the
certificate of title, but only has to rely on the certificate of title. He is charged with notice only of
such burdens and claims as are annotated on the title. The pertinent law on the matter of
burdens and claims is Section 44 of the Property Registration Decree.
Land Titles and Deed Case Digest

Intestate Estate of Don Mariano San Pedro v. Court of Appeals


GR No. 103727, 1 Dec 1996

FACTS

The case involves two petitions which were consolidated by the court in its decision.

Engracio San Pedro, as heir-judicial administrator of Plaintiff Intestate, filed a complaint for
recovery of real property with damages and prayer for preliminary injunction against private
defendants Ocampo, Buhain and dela Cruz. RTC of QC dismissed the complaint saying that the
defendants are already the registered owners covered by the Torrens Title - which cannot be
defeated by the alleged Spanish Title of San Pedro. The Spanish Title also stated that the estate
shall be excluded from the coverage of Titulo Propriedad No. 4136. Petitioner filed an appeal,
CA dismissed.

In another petition, Engracio San Pedro and Justino Benito filed a petition for letter of
administration over the intestate to be appointed as administrator and co-administrator. Judge
Echeverri appointed San Pedro as administrator and the court issued letter of administration in
his favor upon posting a bond of 10,000. Republic of the Philippines filed a motion for
intervention and opposition to the petition, claiming that the Titulo de Propriedad is inadmissible
and ineffective proof of ownership in court and it is invalid. Republic filed a motion to suspend
the proceedings but the Republics opposition to the petition for letter of administration was
dismissed. Republic filed Motion for Recon. The Judge declared Titulo de Propriedad as null
and void and excluded all lands covered from the inventory of the estate of the late Mariano San
Pedro. Petitioner-heirs appealed to CA. CA dismissed.

ISSUE

Whether the lower court committed error in excluding from the inventory of the estate all lands
covered by Titulo de Propriedad No. 4136 on the ground that it is null and void.
Land Titles and Deed Case Digest

RATIO

NO, The lower court did not commit any error when it declared Titulo de Propriedad No. 4136 as
null and void, consequently excluding all lands covered by the said title from the inventory of the
estate. Under PD 892, the system of registration under Spanish Mortgage Law was abolished
and all holders of Spanish Titles should cause their lands to be registered under Land
Registration Act within 6 months from date of effectivity or until August 16, 1976. In both cases,
petitioner-heirs did not adduce evidence to show that Titulo de Propriedad No. 4136 was
brought under the operation of PD 892. There was no certificate of title shown.

Also, Titulo de Propriedad No. 4136, under PD 892, is inadmissible and ineffective as evidence
of private ownership in special proceedings case. Since the Titulo was not registered under
Land Registration Act, said Titulo is inferior to the registered title of defendants Ocampo, Buhain
and dela Cruz. Torrens title of the latter enjoys the conclusive presumption of validity.

Petitioner-heirs failed to present neither the original Titulo nor a genuine copy thereof (only an
alleged illegible copy was presented). Even the secondary evidence presented was also not
admissible.
Republic v. Heirs of Sin
GR No. 157485, 26 March 2014

FACTS
Respondents claim that they are the lawful heirs of the late Maxima Lachica Sin who was the
owner of a parcel of land situated at Barangay Tambac, New Washington, Aklan. On August 26,
1991, the respondent heirs instituted in the RTC of Kalibo, Aklan a complaint against Aklan
National College of Fisheries (ANCF) for recovery of possession, quieting of title, and
declaration of ownership with damages claiming that the latter usurped their rights over the
property.
ANCF countered that the subject land was the subject of Proclamation No. 2074 of then
President Ferdinand E. Marcos allocating the area of said property as civil reservation for
educational purposes of ANCF. The ANCF Superintendent furthermore averred that the subject
parcel of land is timberland and therefore not susceptible of private ownership.
The respondents presented evidence that they inherited a bigger parcel of land from their
mother who acquired it by virtue of a deed of sale. That in 1988 a potion thereof was occupied
by ANCF and converted into a fishpond for educational purpose. Respondent heirs asserted
that they were previously in possession of the disputed land in the concept of an owner. To
prove possession, respondents presented several tax declarations, the earliest of which was in
the year 1945.
Land Titles and Deed Case Digest

The MCTC, the RTC and the Court of Appeals unanimously held that respondents retain private
rights to the disputed property by virtue of their and their predecessors open, continuous,
exclusive and notorious possession amounts to an imperfect title, which should be respected
and protected.
ISSUE

Whether or not the claim of the respondents amounts to judicial confirmation of imperfect title.

RATIO

NO, This Court has thus held that there are two requisites for judicial confirmation of imperfect
or incomplete title under CA No. 141, namely: (1) open, continuous, exclusive, and notorious
possession and occupation of the subject land by himself or through his predecessors-in-
interest under a bona fide claim of ownership since time immemorial or from June 12, 1945; and
(2) the classification of the land as alienable and disposable land of the public domain. With
respect to the second requisite, the courts a quo held that the disputed property was alienable
and disposable before 1960, citing petitioners failure to show competent evidence that the
subject land was declared a timberland before its formal classification as such on said year.
Petitioner emphatically objects, alleging that under the Regalian Doctrine, all lands of the public
domain belong to the State and that lands not appearing to be clearly within private ownership
are presumed to belong to the State.

In the case at bar, it is therefore the respondents which have the burden to identify a positive
act of the government, such as an official proclamation, declassifying inalienable public land
into disposable land for agricultural or other purposes. Since respondents failed to do so, the
alleged possession by them and by their predecessors-in-interest is inconsequential and could
never ripen into ownership. Accordingly, respondents cannot be considered to have private
rights within the purview of Proclamation No. 2074 as to prevent the application of said
proclamation to the subject property.

Republic v. Remman Enterprises Inc.


GR No. 199310, 19 February 2014

FACTS

On December 3, 2001, Remman Enterprises filed an application with the RTC for judicial
confirmation of title over two parcels of land situated in Taguig, Metro Manila, identified as Lot
Nos. 3068 and 3077, Mcadm-590-D, Taguig Cadastre, with an area of 29,945 square meters
and 20,357 sq m, respectively. The RTC found the application for registration sufficient in form
and substance and set it for initial hearing on May 30, 2002. The Notice of Initial Hearing was
published in the Official Gazette and was likewise posted in a conspicuous places. On the day of
Land Titles and Deed Case Digest

the hearing, only the Laguna Lake Development Authority (LLDA) appeared as oppositor.
Hence, the RTC issued an order of general default except LLDA, which was given 15 days to
submit its comment/opposition to the respondents application for registration. Sometime after,
the Republic of the Philippines (petitioner) likewise filed its Opposition, alleging that the
respondent failed to prove that it and its predecessors-in-interest have been in open, continuous,
exclusive, and notorious possession of the subject parcels of land since June 12, 1945 or
earlier.

The RTC ruled in favor of respondent, and was affirmed by the CA.

ISSUE

Whether respondent is entitled to the registration of title to the subject properties?

HELD NO

RATIO

That the subject properties are not part of the bed of Laguna Lake, however, does not
necessarily mean that they already form part of the alienable and disposable lands of the public
domain. It is still incumbent upon the respondent to prove, with well-nigh incontrovertible
evidence, that the subject properties are indeed part of the alienable and disposable lands of
the public domain. In the case at bar, the Court finds that the respondent failed to substantiate
its entitlement to registration of title to the subject properties and they failed to present sufficient
evidence to prove that it and its predecessors-in-interest have been in open, continuous,
exclusive, and notorious possession and occupation of the subject properties since June 12,
1945, or earlier.

Under the Regalian Doctrine, which is embodied in our Constitution, all lands of the public
domain belong to the State, which is the source of any asserted right to any ownership of land.
All lands not appearing to be clearly within private ownership are presumed to belong to the
State. Accordingly, public lands not shown to have been reclassified or released as alienable
agricultural land, or alienated to a private person by the State, remain part of the inalienable
public domain. The burden of proof in overcoming the presumption of State ownership of the
lands of the public domain is on the person applying for registration, who must prove that the
land subject of the application is alienable or disposable. To overcome this presumption,
incontrovertible evidence must be presented to establish that the land subject of the application
is alienable or disposable.
Land Titles and Deed Case Digest

Solid Estate Multi-Products Corporation v. Court of Appeals


GR No. 83383, 6 May 1991

FACTS

On September 28, 1982, filed for a quieting of title against the estate of the respondent Antenor
Virata.

Petitioner claims that the respondent acquired the title to the land by means of fraud which
caused the existence of a cloud on the title.

Petitioner claims that the same bought the land from one Julian Penaranda and was approved
by the Secretary of Agriculture and Commerce.

Respondent Virata denied the allegations in the complaint and presented evidence to prove his
claim over the land. The respondent contended that his predecessor, Mabini Legaspi, bought
the property through a public bidding and was then registered with the Registry of Deeds.

The provincial capitol of Cavite where the Registry of Deeds was housed burned. The land
records and titles were destroyed including to that relating to the subject property.

RTC ruled in favor of Virata. CA affirmed the decision of the RTC.

ISSUE

Whether the respondent is the lawful owner of the subject land.

HELD NO

RATIO

The issuance of a certificate of title in favor of Mabini Legaspi did not vest ownership upon her
over the land nor did it validate the alleged purchase of the lot, which is null and void. Time and
again, it has been held that registration does not vest title. It is merely evidence of such title over
a particular property. Our land registration laws do not give the holder any better title than that
what he actually has.

Although a period of one year has already expired from the time the certificate of title was issued
to Mabini Legaspi pursuant to the alleged sale from the government, said title does not become
incontrovertible but is null and void since the acquisition of the property was in violation of law.
There being no title to the land that Mabini Legaspi acquired from the government, it follows that
Land Titles and Deed Case Digest

no title to the same land could be conveyed by the former to respondent Virata.

The approval by the Secretary of Agriculture and Commerce is indispensable for the validity of
the sale. The fact that there was neither allegation nor proof that the sale to Mabini Legaspi was
with the approval of the Secretary of Agriculture and Commerce. The absence of such approval
made the supposed sale null and void ab initio.

Arceo v. Court of Appeals


GR No. 81401, 18 May 1990

FACTS

It appears that the spouses Abdon Arceo and Escolastica Geronimo were the owners of four
parcels of unregistered land (six were involved but only four were disputed) located in Pulilan,
Bulacan. Escolastica died on September 16, 1942 while Abdon passed away in 1953. They had
one son, Esteban, who died on September 2, 1941. Esteban had five children, Jose, Pedro,
Lorenzo, Antonio, and Sotera. Jose married Virginia Franco, with whom he fathered six children,
Carmelita, Zenaida, Rodolfo, Manuel, Cesar, and Romeo. Pedro, Lorenzo, Antonio, and Sotera
are the private respondents herein while Joses widow, Virginia (Jose died on March 8, 1970),
and their children are the petitioners.

It also appears that on October (or September) 27, 1941 the Arceos executed a deed of
donation inter vivos, in which the spouses bestowed the properties in favor of Jose. Since 1942,
Jose had been paying taxes thereon. In 1949, he took personal possession thereof, worked
thereon, and claimed them as owner thereof.

On October 3 (or 30), 1941, the Arceos supposedly signed a deed of donation mortis causa,
giving away the properties in question in favor of all his grandchildren including Jose. It seems
however that it was notarized only on November 3, 1944, after Escolastica had died. On
January 12, 1972, Virginia, together with her children, filed with the cadastral court an
application for registration in their names.

The cadastral court rejected all three documents and distributed the properties according to the
law on intestate succession.

ISSUE

Whether the cadastral court had jurisdiction to determine conflicting claims of ownership

HELD YES. Petition Granted


Land Titles and Deed Case Digest

RATIO

We have held that under Section 2 of the Property Registration Decree, the jurisdiction of the
Regional Trial Court, sitting as a land registration court, is no longer as circumscribed as it was
under Act No. 496, the former land registration law. We said that the Decree has eliminated the
distinction between the general jurisdiction vested in the regional trial court and the limited
jurisdiction conferred upon it by the former law when acting merely as a cadastral court. The
amendment was aimed at avoiding multiplicity of suits, the change has simplified registration
proceedings by conferring upon the required trial courts the authority to act not only on
applications for original registration but also over all petitions filed after original registration of
title, with power to hear and determine all questions arising from such applications or petitions.

At any rate, we have also stated that the limited-jurisdiction-rule governing land registration
courts is subject to recognized exceptions, to wit, (1) where the parties mutually agreed or have
acquiesced in submitting controversial issues for determination; (2) where they have been given
full opportunity to present their evidence; and (3) where the court has considered the evidence
already of record and is convinced that the same is sufficient for rendering a decision upon such
controversial issues.

By the same token, it has been held that the rule is not, in reality, one of jurisdiction, but rather,
of mere procedure, which may be waived. It is not amiss to state likewise that where the issue,
say, of ownership, is ineluctably tied up with the question of right of registration, the cadastral
court commits no error in assuming jurisdiction over it, as, for instance, in this case, where both
parties rely on their respective exhibits to defeat one anothers claims over the parcels sought to
be registered, in which case, registration would not be possible or would be unduly prolonged
unless the court first decided it.
Land Titles and Deed Case Digest

Sec. of DENR v. Yap


GR No. 167707, 8 October 2008

FACTS

- In 1978, Boracay was declared as a tourist zone and marine reserve under Proclamation No.
1801 and implemented by PTA Circular 3-82.
- Respondents Yap who owns parcels of land in Boracay Claims:
o That the proclamation prevented them from filing an application for judicial confirmation of
imperfect title or survey of land for titling.
o That they or their predecessors were in open, continuous, exclusive and notorious
possession and occupation in Boracay since time immemorial. They also paid realty taxes.
o That Boracay was still susceptible of private ownership.
- The OSG countered that Boracay was an unclassified public forest land which was not available
for disposition.
- RTC ruled that neither Proclamation nor PTA mentioned that lands in Boracay were inalienable.
- CA affirmed RTC.

Dr. Sacay, Gelito, Landowners of Boracay (Petitioner Claimants) vs. Sec. of DENR
Land Titles and Deed Case Digest

GR No. 173775; 8 October 2008


Facts:
- In 2006, Proclamation No. 1064 classified Boracay into 400 hectares or reserved forest
(protected) and 628 hectares of agricultural land (alienable).
- It also provided for a 15m buffer zone on each side of the centerline of roads and trails, reserved
for right-of-way and forms part of reserved forest.
- Petitioners filed with SC for mandamus, prohibition and nullification of the Proclamation.
o The alleged that they had been in continued possession of their lots since time immemorial.
They have also invested billions in developing their lands.
o They also contend that Boracay being classified neither mineral nor timber land is deemed
agricultural which does not need of the proclamation reclassifying it. Thus, they are entitled
to judicial confirmation of title.
- OSG countered that Boracay is an unclassified forest land as such is inalienable.

ISSUE

Whether private claimants have a right to secure titles over their occupied portions in Boracay.

HELD: NO

RATIO

No. Prior to Proclamation 1064 Broacay had never been classified as alienable, it was an
unclassified land of public domain. It is up to the State if it will be disposed for private ownership.
There must be a positive act of the President declaring as alienable and disposable.

The cases of Ankron and De Aldecoa that claimants rely on were decided before the President
had the authority to classify lands. The court were then free to make classifications and had the
right to presume that lands are agricultural until the contrary is shown. However, not all lands of
public domain had been automatically reclassified as alienable agricultural lands and take lands
out of State ownership. This would be inconsistent with the Regalian Doctrine. Since the 1919
Public Land Act the President had the exclusive prerogative to classify public lands. When Act
No. 926 was superseded by the 1919 Public Land Act, without an application for judicial
confirmation filed by private claimants or their predecessors, the courts were no longer
authorized to determine the propertys land classification.

The continued possession of private claimants for 10yrs as required under Act 926 did not
create the presumption that the lands are alienable. The assumption is that title to public lands
remained in the government.
Land Titles and Deed Case Digest

Even though there has been a lot of commercial development in Boracay it still remains to be
public forest. The classification is descriptive of its legal nature and does not have to be
descriptive of what the land actually looks like.

Proclamation 1801 did not classify Boracay as alienable even if it made it into a tourist zone. It
did not identify what was alienable and what was forest land as it was done in Proclamation
1064.

There are 2 requisites for judicial confirmation of imperfect or incomplete title under CA No. 141.
1) Open, continuous, exclusive, and notorious possession and occupation of the land under a
bona fide claim of ownership since time immemorial or from June 12 , 1945; 2) the classification
of the land as alienable and disposable land of the public domain.

They cannot claim under Proclamation 1064 as they failed to prove the first requirement. The tax
declaration are insufficient being the earliest was issued in 1993.

Cruz v. Sec. of DENR


Land Titles and Deed Case Digest

GR No. 135385, 6 December 2000

FACTS:

Petitioners Isagani Cruz and Cesar Europa filed a suit for prohibition and mandamus as citizens
and taxpayers, against the Secretary of the Department of Environment and Natural Resources,
Angel Alcala.

The petitioners assail certain provisions of the IPRA and its IRR on the ground that these
amount to an unlawful deprivation of the States ownership over lands of the public domain as
well as minerals and other natural resources therein, in violation of the Regalian doctrine
embodied in section 2, Article XII of the Constitution as the Secretary of DENR allowed the
delineation of ancestral domains special task forces and ensured the issuance of Certificates of
Ancestral Land Claims and Certificates of Ancestral Domain Claims to Indigenous People (IPs).

The IPRA law basically enumerates the rights of the indigenous peoples over ancestral domains
which may include natural resources.

In addition, Cruz et al contend that, by providing for an all-encompassing definition of ancestral


domains and ancestral lands which might even include private lands found within said areas,
Sections 3(a) and 3(b) of said law also violate the rights of private landowners.

IPRA provides:

The Indigenous Peoples Rights Act (IPRA) grants the indigenous cultural communities or
indigenous peoples (ICCs/IPs) the ownership and possession of their ancestral domains and
ancestral lands, and defines the extent of these lands and domains, and the ownership given is
the indigenous concept of ownership under customary law which traces its origin to native title.

ISSUE:

Whether or not the IPRA law is unconstitutional. NO

RATIO:

The provisions of IPRA do not contravene the Constitution. Examining the IPRA, there is
nothing in the law that grants to the ICCs/IPs ownership over the natural resources within
their ancestral domain. Ownership over the natural resources in the ancestral domains
remains with the State and the rights granted by the IPRA to the ICCs/IPs over the natural
resources in their ancestral domains merely gives them, as owners and occupants of the land
Land Titles and Deed Case Digest

on which the resources are found, the right to the small scale utilization of these resources, and
at the same time, a priority in their large scale development and exploitation.

Additionally, ancestral lands and ancestral domains are not part of the lands of the public
domain. They are private lands and belong to the ICCs/IPs by native title, which is a
concept of private land title that existed irrespective of any royal grant from the State.
However, the right of ownership and possession by the ICCs/IPs of their ancestral domains is a
limited form of ownership and does not include the right to alienate the same.

The Supreme Court deliberated upon the matter. After deliberation they voted and reached a 7-7
vote. They deliberated again and the same result transpired. Since there was no majority vote,
Cruzs petition was dismissed and the constitutionality of the IPRA law was sustained.

Republic vs Agunoy
GR No. 155394, 17 February 2005

FACTS:

ISSUE:

HELD:

RATIO:
Land Titles and Deed Case Digest

Republic vs Naguiat
GR No. 134209, 24 January 2006

FACTS:

- Naguiat filed an application for registration of title of 4 parcels of land which she purchased from
LID Corp. which acquired them from Calderon, Moraga, and Monje and their predecessors-in-
interest who have been in possession for more than 30yrs.
- RP filed an opposition contending that neither applicant nor her predecessors-in-interest have in
open, continuous, exclusive, and notorious possession and occupation of the lands since 12
June 1945 or earlier. Also, that the documents of title and tax payment receipts do not
constitute sufficient evidence.
- RP also stated that the Naguiats claim of ownership in fee simple base on Spanish title or grant
can no longer be availed of and that the lands are part of the public domain belonging to RP
not subject to private appropriation.
- Trial court granted Naguiats application. CA affirmed trial court.

ISSUE:

Whether the lands are alienable. No.

RATIO:

All lands of the public domain belong to the State. All lands not appearing of private dominion
presumptively belong to the State. Public lands not shown to have been reclassified or released
Land Titles and Deed Case Digest

as alienable agricultural land or alienated to a private person by the State remain part of the
inalienable public domain.

Naguiat never presented the required certification from the proper govt agency or official
proclamation reclassifying the land applied as alienable and disposable. Matters of land
classification or reclassification cannot be assumed.