Republic v. Lensico
REITERATIONFacts
The Antecedents: The subject property, Lot No. 2833 of the Naic Estate, with an area of 16,459 square meters, was originally part of Friar Lands. Melanio Lensico, the occupant for 34 years, filed an Application to Purchase Friar Lands in 1964, which was approved, and a Sales Contract was executed. Subsequently, Transfer Certificate of Title (TCT) No. T-78832 was issued in the names of Melanio Lensico and his wife, Donata Mojica. After their death, their children and heirs (respondents) demanded rentals from Cavite College of Fisheries (petitioner), which occupied a portion of the land (11,650 sq. meters) since 1961. The Republic of the Philippines (petitioner) also sought to cancel the issued TCT, claiming the lot was foreshore land and part of the public domain. Procedural History: The Lensicos filed Civil Case No. NC-934 for Recovery of Possession of Property or Payment of Price against Cavite College. The Republic filed Civil Case No. NC-963 for Annulment of Title and Reversion of Land to the State against the Lensicos and the Register of Deeds. The two cases were consolidated. The Regional Trial Court (RTC) ordered Cavite College to pay the Lensicos the price of ₱25.00 per square meter for the occupied portion or reasonable rent of ₱2,000.00 per month from July 1961 until December 1999, with an option for an extended period. The RTC also awarded attorney's fees and costs. The Court of Appeals (CA) affirmed the RTC decision except for the award of attorney's fees and costs, which it deleted. The Petition: The Republic of the Philippines and Cavite College of Fisheries filed a Petition for Review with the Supreme Court, assailing the CA decision, primarily arguing that the CA erred in dismissing their appeal on the ground that the subject property is not foreshore land and that the respondents' predecessor-in-interest did not commit fraud in securing the title.
Issue(s)
Whether the Court of Appeals erred in dismissing the petitioners' appeal on the ground that the subject property is not part of foreshore land and that respondents’ predecessor-in-interest did not commit fraud in securing a certificate of title over the subject property. Whether respondents’ predecessor was the lawful owner of the parcel of land occupied by petitioner school.
Ruling
The Supreme Court denied the Petition for Review and affirmed the Decision of the Court of Appeals. The Court held that the subject property was friar land and not foreshore land, and that the Certificate of Title issued to respondents' predecessor was valid and not fraudulently obtained. The Court reiterated its policy of not disturbing the factual findings of the Court of Appeals when affirmed by the trial court, absent any of the enumerated exceptions, which were not present in this case. The Court also affirmed the basis for the purchase price as determined by the lower courts.
Ratio Decidendi
On the Nature of the Property and Allegations of Fraudulent Acquisition of Title: The Court reiterated the well-established doctrine that factual findings of the Court of Appeals, affirming those of the trial court, are final and conclusive and cannot be disturbed in a petition for review under Rule 45 of the Rules of Court. Petitioners failed to establish any of the exceptions that would warrant a review of these factual findings. The lower courts had determined that the lot was part of the friar lands titled since 1913 and was not foreshore land. Although corners of the lot adjoined the sea, it was not proven that these areas were covered by water during high tide, thus failing to meet the definition of foreshore land. The registration of the property under Act No. 496 since February 4, 1913, further dispelled its public nature. The Court held that whether fraud attended the application for the title is a factual question. Petitioners failed to adduce sufficient evidence to establish fraud in the issuance of the title to Melanio Lensico. Mere allegations that Lensico was illiterate and that someone else completed the application without his verification were unsupported by evidence. The claim that the investigation was not actual was countered by the presumption that official duty has been regularly performed, and the investigation could have been conducted on contiguous weekdays. The existence of buildings constructed by Cavite College did not preclude Lensico from being the actual occupant of other portions of the lot, and his possession prior to the College's entry was not disproven. The Court found no willful and knowing false statement by Lensico that would warrant cancellation of the application and forfeiture of payments. On the Basis for Purchase Price and Lawful Ownership: The Court affirmed the trial court's determination, affirmed by the CA, that the just compensation for the taking of the subject portion of the land was ₱25 per square meter or a monthly rent of ₱2,000.00. The Court noted that in expropriation proceedings, the value of the land and its character at the time it was taken by the government are the criteria for determining just compensation. The petitioners did not seriously assail the justness of this determination, which was factual in nature. Therefore, the Court found no compelling reason to disturb this finding.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' ruling that the subject property was friar land and not foreshore land, and that the Certificate of Title was not fraudulently obtained. The Court reiterated that factual findings of the Court of Appeals affirming those of the trial court are final and conclusive and cannot be disturbed in a petition for review under Rule 45, absent specific exceptions which were not present in this case. The Court also held that the basis for purchase price in expropriation proceedings should be the value at the time of taking.