Trinidad Diaz-Enriquez v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Petitioner Trinidad Diaz-Enriquez purchased two parcels of land from Ricardo Pereña, Remedios Pereña-Panganiban, and Celsa Resplandor via an extrajudicial partition with absolute sale on April 19, 1975. On December 11, 1992, petitioner filed an application for land registration for Lot 277 (Portion C) Cads. 617-D, with an area of 6,917 square meters, before the RTC of Naic, Cavite, Branch 15, docketed as LRC Case No. NC-455. She filed five other similar applications for adjacent parcels. Procedural History: The Republic of the Philippines, represented by the Director of Lands, opposed the application, asserting that neither the applicant nor her predecessors-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945, or earlier, and that the parcels were portions of the public domain. The RTC issued an Order of General Default due to the respondent's failure to appear. Subsequently, petitioner sold the property to Dr. Rebecco E. Panlilio, who then sold it to Puerto Azul Land, Inc. (PALI). PALI was substituted as the applicant. PALI presented Engr. Angel R. Salvacion as its sole witness, who testified about the company's possession and improvements on the land. The RTC granted the application for registration on March 22, 1996, confirming the applicant's title. The Republic appealed to the Court of Appeals (CA), arguing insufficient proof of the land's identity and the applicant's registrable title. The CA reversed the RTC's decision on January 7, 1999, dismissing the application. The CA denied petitioner's motion for reconsideration on December 14, 1999. The Petition: Petitioner filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution, alleging grave error in holding that the parcel of land sought to be registered was not the same land purchased by petitioner and that she failed to prove open, continuous, exclusive, and notorious possession.
Issue(s)
Whether petitioner Trinidad Diaz-Enriquez is the real party-in-interest. Whether the parcel of land sought to be registered is the same or part of the land purchased by petitioner from the Pereña heirs. Whether petitioner and her predecessors-in-interest proved open, continuous, exclusive, and notorious possession of the subject parcel of land for the required number of years.
Ruling
The petition is DENIED. The decision of the Court of Appeals is AFFIRMED. LRC Case No. NC-455 is hereby ordered DISMISSED.
Ratio Decidendi
On the issue of the real party-in-interest: The Supreme Court ruled that petitioner Trinidad Diaz-Enriquez is not the real party-in-interest. She sold the property subject of the application to PALI on October 27, 1994, and PALI was substituted as the applicant in the trial court. Under Rule 45 of the Rules of Court, only the aggrieved party may file a petition for review on certiorari. Since PALI was the party-appellee in the CA and the aggrieved party by the adverse ruling, it was the proper party to file the petition, not the petitioner who had already divested herself of interest in the property. The Court reiterated the doctrine that every action must be prosecuted in the name of the real party-in-interest, who is the one who stands to be benefited or injured by the judgment. On the identity of the land: The Court agreed with the Court of Appeals that the parcel of land sought to be registered (Lot 277, Portion C, Cads. 617-D, with an area of 6,917 square meters) had different technical descriptions and boundaries from the parcels of land described in the extrajudicial partition with absolute sale executed by the Pereñas in favor of Enriquez, which had an area of 1,096,433 square meters. The petitioner failed to sufficiently and satisfactorily identify the lot sought to be registered as the same or part of the lot she purchased, thus failing to prove that the property sought to be registered was included in the deed of extrajudicial partition with absolute sale. The Court emphasized that a person seeking registration must prove their claim by clear and convincing evidence. On possession and ownership: The Supreme Court affirmed the CA's finding that the petitioner failed to prove that she and her predecessors-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the subject property under a bona fide claim of ownership since June 12, 1945, or earlier. The sole witness, Engr. Salvacion, admitted he was employed by PALI only in 1993 and first saw the property then, lacking personal knowledge of the predecessors' possession. His testimony regarding the earliest tax payment in 1961 was not sufficiently substantiated, and tax declarations alone are not sufficient proof of possession, much less ownership. The Court reiterated that the burden of proof is on the applicant to show by clear, positive, and convincing evidence that the possession was of the nature and duration required by law.
Main Doctrine
A party seeking registration of title must prove by clear and convincing evidence that the land sought to be registered is the same land described in the application and that the applicant is the owner thereof. Mere tax declarations are insufficient proof of possession and ownership.