Recto v. Republic
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the application for registration of title over a 23,209 square meter lot, Lot 806, Cad-424, Sto. Tomas Cadastre, situated in Barangay San Rafael, Municipality of Sto. Tomas, Province of Batangas. The petitioners, Spouses Philip Recto and Ester C. Recto, purchased the lot from sisters Rosita Medrana Guevarra and Maria Medrana Torres, who inherited it from their parents. The predecessors-in-interest claimed ownership and possession of the lot since 1945 or earlier, cultivating it and paying taxes thereon. The lot was confirmed to be within the alienable and disposable zone and agricultural in nature. 2. Procedural History: The petitioners filed an application for registration of title with the Regional Trial Court (RTC) of Tanauan, Batangas, Branch 6. The RTC granted the petition, adjudicating the lot in favor of the Spouses Recto. The Republic of the Philippines, through the Solicitor General, appealed to the Court of Appeals (CA), arguing that the petitioners failed to present the original tracing cloth plan, prove possession for the required period, and overcome the presumption that the property is part of the public domain. The CA reversed the RTC's decision solely on the ground of the failure to submit the original tracing cloth plan. The petitioners moved for reconsideration, which was denied by the CA. 3. The Petition: The petitioners filed a petition for review on certiorari with the Supreme Court, seeking to reverse the CA's decision and reinstate the RTC's ruling. They argued that they had met all the requirements for registration, including providing sufficient evidence to identify the land. They also presented a certified true copy of the original tracing cloth plan and a certification from the Land Registration Authority that the original plan is on file. The Solicitor General, in the interest of justice, did not oppose the petition, acknowledging the expenses and time petitioners would incur if the case were refiled. The Supreme Court considered whether the blueprint copy of the plan and technical description, along with other submitted documents, were sufficient to identify the land for registration purposes, despite the absence of the original tracing cloth plan.
Issue(s)
Whether petitioners sufficiently proved their open, continuous, exclusive, and notorious possession and occupation of the subject land under a bona fide claim of ownership since June 12, 1945, or earlier. Whether the subject land is alienable and disposable land of the public domain. Whether the presentation of a blueprint copy of the survey plan, along with its technical description, is sufficient to identify the land for registration purposes in lieu of the original tracing cloth plan.
Ruling
The Supreme Court reversed and set aside the decision and resolution of the Court of Appeals, and reinstated the decision of the Regional Trial Court, ordering the issuance of a decree of registration over Lot 806 in favor of the petitioners.
Ratio Decidendi
On the issue of possession and claim of ownership: The Court found that the predecessors-in-interest, Rosita and Maria, categorically testified to their and their father's possession of Lot 806 in the concept of owners. Their testimonies, given their ages at the time they became aware of their father's possession (13 years old), were found credible by the trial court, which is in a better position to assess witness credibility. The existence of a 1948 Tax Declaration that canceled a previous one further substantiated possession prior to that date, and the Court reiterated that belated tax declarations do not necessarily negate possession since 1945 or earlier, citing Republic v. Court of Appeals. The Court affirmed that petitioners met the requirement of open, continuous, exclusive, and notorious possession and occupation of alienable and disposable land under a bona fide claim of ownership since June 12, 1945, or earlier. On the issue of the land being alienable and disposable: The Court confirmed that Lot 806 is indeed alienable and disposable land of the public domain, as certified by the DENR. Reports indicated that the entire area is within an alienable and disposable zone, classified as agricultural, not within a reservation or forest zone, and does not encroach upon any established watershed, riverbed, or riverbank protection. This met the second requisite for original registration. On the sufficiency of the blueprint copy of the plan: The Court acknowledged that the submission of the original tracing cloth plan is a mandatory requirement. However, it clarified that blueprint copies and other evidence could also provide sufficient identification, citing Republic v. Court of Appeals and Director of Lands v. Court of Appeals. In the present case, the blueprint copy of Plan Ap-04-010485 and its technical description, both certified by the Land Management Services, DENR, were deemed sufficient to identify the land. Furthermore, petitioners submitted a certified true copy of the original tracing cloth plan and a certification from the Land Registration Authority that the original plan is on file. Therefore, the Court of Appeals erred in reversing the trial court's decision solely on the ground of failure to present the original tracing cloth plan.
Main Doctrine
A blueprint copy of a survey plan, along with its technical description duly certified by the Land Management Services of the DENR, can sufficiently identify a land for registration purposes, even in the absence of the original tracing cloth plan, provided that the correctness of the blueprint and technical description are certified.