Republic v. Development Resources Corp.
REITERATIONFacts
The Antecedents: On October 14, 1922, the Court of First Instance of Davao adjudicated Lot 544 to Antonio Matute. Subsequently, Original Certificate of Title (OCT) 493 was issued, from which several transfer certificates of title (TCTs) were derived, including TCT 44671 (Lot 1) and TCT 44675 (Lot 5) in the name of respondent Development Resources Corporation (DRC). Procedural History: On April 5, 1993, the Republic of the Philippines (Republic), through the Office of the Solicitor General, filed a complaint before the Regional Trial Court (RTC) of Davao City seeking the cancellation of TCT 44671 and TCT 44675 and the reversion of Lots 1 and 5 to the public domain. The Republic alleged that these lots were still part of the public forest and inalienable on October 14, 1922, the date of adjudication to Matute, and were only declared alienable on August 6, 1923, based on Land Classification (LC) Map 47. DRC contended that its lots were already private properties held by purchasers in good faith. The RTC dismissed the complaint, finding that the Republic failed to prove the lots were still public domain at the time of adjudication and that LC Map 47 lacked probative value. The Court of Appeals affirmed the RTC's decision. The Petition: The Republic elevated the case to the Supreme Court, questioning whether DRC's titles could be cancelled based on LC Map 47 indicating the lots were inalienable at the time of adjudication.
Issue(s)
Whether respondent DRC’s titles over Lots 1 and 5 of Pcs-16678 of the Davao Cadastre can be cancelled, having been supposedly issued when, based on LC Map 47, these lots were still inalienable lands of the public domain. Whether the Republic discharged its burden of proof to warrant the cancellation of registered titles and reversion of land to the public domain.
Ruling
The petition is DENIED for lack of merit.
Ratio Decidendi
On the issue of whether respondent DRC’s titles can be cancelled: The Court held that the Republic failed to discharge its heavy burden of proving the ground for reversion. The Republic presented only an electronic reproduction of LC Map 47, which has no probative value. A mere photocopy of an LC Map is not competent evidence. While evidence is admissible when the original is in the custody of a public officer, a certified copy issued by the custodian is required to prove its contents. The copy presented was neither marked nor certified as a reproduction of the original, thus it could not be considered an official or original copy. On the issue of whether the Republic discharged its burden of proof: The courts below correctly held that LC Map 47 does not state on its face that Lot 544 became alienable and disposable only on August 6, 1923, the date appearing on the map. The map was certified on that date, but this does not conclusively establish that the land was classified as alienable and disposable only on that specific date. The DENR certification had no additional value as it was based on the same map. Similar to the ruling in Sta. Monica Industrial and Development Corporation v. Court of Appeals, where an LC Map did not conclusively state the classification of the land at the time of adjudication, the Republic's evidence was insufficient. The fact that the lots were part of a cadastral survey initiated by the government to encourage titling does not aid the Republic's case. Therefore, the courts below correctly dismissed the reversion suit for failure of the Republic to discharge its evidential burden.
Main Doctrine
The State bears a heavy burden of proving the ground for reversion, and a mere photocopy of a Land Classification Map, without being certified, has no probative value to prove that land was inalienable at the time of adjudication.