Republic v. San Mateo
REITERATIONFacts
The Antecedents: Respondents Apostolita San Mateo, Brigida Tapang, Rosita Accion, and Celso Mercado filed a petition for registration of title over a 12,896 square-meter parcel of land in Ibayo, Napindan, Taguig City. They claimed ownership through inheritance from their grandfather, Leocadio Landrito, whose possession of a portion of the land was evidenced by a 1948 Tax Declaration. The property was subsequently inherited by Leocadio's children, and through a series of waivers of rights and extra-judicial settlements, the respondents, as heirs of Crisanta, consolidated ownership. The petition was opposed by Globe Steel Corporation, New Donavel Compound Neighborhood Association, Inc., and the Laguna Lake Development Authority, raising concerns about property encroachment, prior right of possession due to land filling, and the land's status as part of the Laguna Lake bed. Procedural History: The respondents' petition for land registration was initially filed before the Regional Trial Court (RTC) of Pasig City. After proceedings, the RTC rendered a decision on November 3, 2010, granting the registration of the title in favor of the respondents, finding sufficient evidence of possession since 1948 and that the land was alienable and disposable. The Republic of the Philippines, through the Office of the Solicitor General, appealed this decision to the Court of Appeals (CA). The CA, in its decision dated September 14, 2012, affirmed the RTC's ruling, holding that the RTC acquired jurisdiction through proper publication and that the respondents had sufficiently proven the land's alienability and their possession. The Republic then filed the present Petition for Review on Certiorari before the Supreme Court. The Petition: The Republic of the Philippines, through a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeks to reverse the CA's decision. The Republic argues that the RTC did not acquire jurisdiction due to defective notice, that the respondents failed to prove absolute ownership and possession of the entire land, and crucially, that they failed to establish that the land is part of the alienable and disposable public domain. The Supreme Court, while agreeing that the RTC acquired jurisdiction, found that the respondents failed to adequately prove the land's alienability, citing the insufficiency of a mere CENRO certification without proof of the DENR Secretary's approval, and distinguishing the present case from prior rulings that allowed substantial compliance. Consequently, the Court reversed the decisions of the lower courts, denying the respondents' application for registration.
Issue(s)
Whether the trial court acquired jurisdiction over the case. Whether the respondents have possessed the property for the length of time required by law. Whether respondents proved that the property is alienable and disposable.
Ruling
The Supreme Court granted the petition, reversing and setting aside the decisions of the Court of Appeals and the Regional Trial Court. The application for registration of title was denied.
Ratio Decidendi
On the issue of jurisdiction: The Court affirmed the CA's ruling that the RTC properly acquired jurisdiction. It reiterated that a petition for land registration is an action in rem, and thus, publication of the notice of hearing, along with the technical description of the property, is sufficient to vest the trial court with jurisdiction over the res. The Court also held that the amendment of the technical description, which resulted in a reduction of the area, did not require republication as the amended area was already included in the initial publication and did not involve an addition of land not previously covered. On the issue of possession: The Court found that the issue of possession is a question of fact, and the RTC, as the trial court, is in the best position to evaluate the evidence. The Court found no reversible error in the CA's affirmance of the RTC's reliance on the tax declarations presented by the respondents as sufficient proof of their possession of the subject property since 1948. On the issue of alienability and disposability: The Court found that the respondents failed to prove that the subject property is alienable and disposable. While the respondents presented a certification from the DENR-South CENRO, the Court emphasized that this is insufficient without proof that the DENR Secretary approved such certification. Citing Republic v. T.A.N. Properties, Inc., the Court held that strict compliance requires both a CENRO/PENRO certification and a certified true copy of the DENR Secretary's original classification. The Court clarified that the pro hac vice exception in Republic v. Vega, which allowed substantial compliance, was not applicable here because the RTC decision was rendered after the rule on strict compliance was established in T.A.N. Properties, giving respondents ample opportunity to present the required evidence, which they failed to do. The Court noted that the CENRO certification was the sole evidence presented by the respondents to prove alienability, which is wanting.
Main Doctrine
A CENRO certification that a property is alienable, without proof of the DENR Secretary's approval of such certification, is insufficient to support a petition for land registration. Strict compliance with the rule requiring both a CENRO/PENRO certification and a certified true copy of the DENR Secretary's original classification is generally required, although substantial compliance may be considered pro hac vice under specific circumstances.