Republic v. Sodsod
REITERATIONFacts
1. The Antecedents: The Director of Lands initiated cadastral proceedings to register lands within Oas Cadastre, Albay. Spouses Gerardo Sodsod and Felicidad Rellores filed a claim for Lot No. 10367, asserting ownership based on over thirty years of possession, including that of their predecessor-in-interest, since 1929. The lot remained uncontested during the cadastral hearings. 2. Procedural History: The Regional Trial Court of Albay, on July 27, 1990, ordered the registration and confirmation of Lot No. 10367 in the names of Gerardo Sodsod and Felicidad Rellores. The Republic of the Philippines, represented by the Director of Lands, appealed this decision to the Court of Appeals. On July 25, 1994, the Court of Appeals affirmed the trial court's ruling. 3. The Petition: The Republic of the Philippines, through the Director of Lands, filed a petition for review on certiorari with the Supreme Court, seeking to overturn the Court of Appeals' decision. The core issue presented was whether the respondent and his predecessor-in-interest had possessed the land for the requisite period to establish registrable title under Section 48(b) of Commonwealth Act No. 141. The Supreme Court found that the factual findings of the Court of Appeals were conclusive and agreed that the respondent had met the requirements for confirmation of title.
Issue(s)
Whether respondent and his predecessor-in-interest possessed the land in question for more than thirty years sufficient to vest in him registrable title over the same.
Ruling
The Supreme Court dismissed the appeal and affirmed in toto the decision of the Court of Appeals, upholding the registration and confirmation of Lot No. 10367 in the names of Gerardo Sodsod and Felicidad Rellores.
Ratio Decidendi
On the issue of possession for more than thirty years sufficient to vest registrable title: The Court held that the issue is factual and that the findings of the Court of Appeals are conclusive and may not be reviewed on appeal. The Court found that respondent Sodsod and his predecessor-in-interest had been in actual, open, continuous, exclusive, peaceful, and notorious possession and occupation of the lot involved in the concept of owners since 1929 up to the filing of the cadastral case. This period of possession exceeded thirty (30) years, thereby complying with the requirements under Section 48(b) of Commonwealth Act No. 141. Consequently, they had acquired private ownership of the land and were entitled to the confirmation of registrable title. The Court reiterated that ipso jure, respondent acquired private ownership of the land by mere possession and occupation for more than thirty (30) years under claim of ownership, citing established jurisprudence.
Main Doctrine
Possession and occupation of land for more than thirty (30) years under claim of ownership, in the concept of owner, openly, continuously, adversely, notoriously, and exclusively, is sufficient to acquire private ownership and entitle the possessor to confirmation of registrable title under Section 48(b) of Commonwealth Act No. 141.