Republic v. Recio
REITERATIONFacts
The Antecedents: The underlying dispute concerns the registration of title to Lot No. 900 of the Pilar Cadastre. In 1977, Rizal Recio, on behalf of himself and his siblings Oscar, Teresita, and Paciencia Recio, applied for the registration of title to this lot. The Regional Trial Court (RTC) of Roxas City, Branch 18, granted this application on September 14, 1984, ordering the confirmation and registration of title in the names of the Recio heirs. Subsequently, Original Certificate of Title (OCT) No. 0-2107 was issued in their favor. Procedural History: In 1997, occupants of Lot No. 900 filed a protest with the Department of Environment and Natural Resources (DENR) alleging that the land was within forest lands and thus not subject to private appropriation. An investigation by a DENR Special Investigator concluded that Lot No. 900 indeed fell within forest lands. Consequently, the Republic of the Philippines, represented by the DENR, filed a petition for annulment of judgment with the Court of Appeals (CA) in 2002, seeking to nullify the RTC's 1984 decision on the grounds of lack of jurisdiction. The CA, after a referral to another RTC judge for evidence reception, ultimately dismissed the DENR's petition on May 25, 2006, finding insufficient proof that the land was forest land and noting the inadmissibility of photocopied evidence. The Petition: The Republic of the Philippines, through the DENR and the Office of the Solicitor General (OSG), filed this petition for review on certiorari under Rule 45 of the Rules of Court. The petitioner argues that the RTC lacked jurisdiction to adjudicate title to the subject land because it is forest land, which is inalienable and cannot be subject to private appropriation, citing Section 14 of Presidential Decree No. 1529. The petitioner further contends that it discharged its burden of proving the inalienable character of the land through official reports and testimonies, and that the CA erred in dismissing its petition for annulment of judgment.
Issue(s)
Whether the RTC acted without jurisdiction in allowing the registration of the subject land. Whether the petitioner discharged the burden of establishing the inalienable and indisposable character of the subject parcel of land.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the RTC had jurisdiction to adjudicate title to the land because, at the time of the application for registration in 1977 and the RTC's decision in 1984, the land was classified as alienable and disposable. The Court also agreed with the CA that the petitioner failed to discharge its burden of proof to establish the inalienable character of the land, as its evidence was insufficient to overcome the prior certification classifying the land as alienable and disposable.
Ratio Decidendi
On the issue of jurisdiction: The Court disagreed with the petitioner's contention that the RTC acted without jurisdiction. It was established that at the time the Recios filed their application for registration in 1977 and when the RTC rendered its decision in 1984, Lot No. 900 was classified as alienable and disposable land. This was supported by a Certification dated November 8, 1976, from the Bureau of Forest Development, which stated that the land was within the alienable and disposable land block of LC Project No. 20. Therefore, the RTC had the jurisdiction to adjudicate title to the land, as it was not forest land at that material time. The subsequent classification of the land as forest land under Project 20-A in 1986, after the RTC decision, did not divest the RTC of its jurisdiction over the case. On the burden of proof: The Court affirmed the Court of Appeals' finding that the petitioner failed to discharge its burden of establishing the inalienable character of the land. The petitioner's evidence consisted of testimonies, a written report, and a photocopy of a sketch plan, which the CA found to be insufficient. The CA correctly noted that a mere photocopy of a sketch plan is inadmissible under the Best Evidence Rule without a showing that the original was lost or destroyed. Furthermore, the petitioner failed to present the land classification map that would have substantiated its claim that Lot No. 900 falls within forest lands, thereby failing to refute the earlier certification classifying it as alienable and disposable. The findings of fact of the Court of Appeals are conclusive on the Supreme Court, absent any showing that they were not supported by evidence on record.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' dismissal of the petition for annulment of judgment, holding that the petitioner failed to sufficiently prove that the subject land was inalienable forest land at the time of the original registration proceedings, and that the RTC had jurisdiction to adjudicate title to the land which was classified as alienable and disposable at that time.