Republic v. Yulo
REITERATIONFacts
The Antecedents: Spouses Santiago and Maria Samson owned parcels of land covered by Tax Declaration Nos. 21671 and 10353. After their death, their heirs executed an extrajudicial settlement and ratification of an absolute deed of sale, dividing the land. Marceliano Samson acquired all shares of his co-heirs over the land. Marceliano died intestate, leaving a parcel of land containing an area of 1,270 sq. m. Fe Ramona Versoza Samson and respondent Katrina Isabel Samson Yulo, a compulsory heir of Marceliano, executed a deed of extrajudicial settlement of estate over the 1,270 sq. m. parcel of land, dividing it between themselves. Procedural History: Respondent filed an application for registration of title over her share of the property in the Municipal Trial Court (MTC) of Lingayen, Pangasinan. The MTC granted the application. The Republic of the Philippines appealed to the Court of Appeals (CA), which affirmed the MTC decision. The CA denied reconsideration. Hence, this petition. The Petition: The Republic of the Philippines filed a petition for review on certiorari, raising two issues: (1) whether the land claimed by respondent is included in the land she inherited from Marceliano, and (2) whether the imposition of costs against petitioner is proper.
Issue(s)
Whether the land claimed by respondent is included in the land she inherited from Marceliano. Whether the imposition of costs against petitioner is proper.
Ruling
The petition is partially meritorious. The imposition of costs against petitioner is deleted.
Ratio Decidendi
On the issue of whether the land claimed by respondent is included in the land she inherited from Marceliano: The Court disagreed with the petitioner's argument that the land acquired by Marceliano had an area of "six (6) ares and eighty six (86) centares" (686 sq. m.), which was smaller than the parcel divided by respondent and Versoza Samson (1,270 sq. m.). The Court held that the identification of the land being claimed is a factual finding supported by evidence and cannot be disturbed in a petition for review on certiorari. Both the CA and MTC found that the subject land was a portion of the land inherited by the respondent from her predecessor, considering the total land area covered by the tax declarations. The Court found no reason to disturb this factual determination. On the issue of whether the imposition of costs against petitioner is proper: The Court agreed with the petitioner that costs should not have been imposed on it. Section 1, Rule 142 of the Rules of Court provides that "No costs shall be allowed against the Republic of the Philippines unless otherwise provided by law." The CA did not cite any provision of law authorizing such imposition of costs. Therefore, the assessment of costs against the petitioner was unwarranted and violative of the aforequoted provision of the Rules of Court.
Main Doctrine
Costs shall not be allowed against the Republic of the Philippines unless otherwise provided by law.