Republic v. Galeno
REITERATIONFacts
1. The Antecedents: Respondent Carmen Santorio Galeno, as a co-owner, filed a petition to correct the land area of Lot No. 2285, covered by Original Certificate of Title (OCT) No. 46417. The title indicated an area of 20,948 square meters, but a resurvey for partition purposes, conducted in accordance with the approved subdivision plan by the Department of Environment and Natural Resources (DENR), revealed the area to be 21,298 square meters. Respondent alleged that she had notified the adjoining owners of the property. 2. Procedural History: The petition for correction was filed before the Regional Trial Court (RTC) of Dumangas, Iloilo, Branch 68. With no opposition, the RTC allowed the presentation of evidence ex parte and, in an Order dated October 13, 2006, granted the petition, directing the Register of Deeds to amend the title. The Republic of the Philippines, through the Office of the Solicitor General, moved for reconsideration, arguing that adjoining owners had not been notified, which is a jurisdictional requirement. The RTC denied this motion in an Order dated January 22, 2007, finding that notice had been sent. The Republic appealed to the Court of Appeals (CA). 3. The Petition: The Court of Appeals, in a Decision dated June 27, 2013, affirmed the RTC's ruling, finding that the respondent had sufficiently proven the correct area based on DENR records and that the Republic had failed to present contrary evidence. The CA also noted the lack of objection from the notified adjoining owners. The Republic's motion for reconsideration was denied. The Republic then filed this petition for review on certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in upholding the correction of the land area, primarily contending that the documentary evidence presented by the respondent lacked probative value as the issuing public officers did not testify in court to validate the facts stated therein.
Issue(s)
Whether the Court of Appeals erred in upholding the correction of the area of the subject property in OCT No. 46417. Whether the documentary evidence presented by the respondent, consisting of DENR certifications and technical descriptions, possessed sufficient probative value to warrant the correction of the land title's area.
Ruling
The petition is granted. The assailed Decision and Resolution of the Court of Appeals are reversed and set aside. The petition for correction of area of Lot No. 2285 on Original Certificate of Title No. 46417 is dismissed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in upholding the correction of the area of the subject property in OCT No. 46417: The Supreme Court held that the Court of Appeals erred in upholding the correction. A scrutiny of the evidence presented by the respondent revealed a failure to establish a sufficient basis for the correction of the area in OCT No. 46417. The Court emphasized that the respondent's documentary evidence, namely the Certification from the DENR, the technical description of Lot No. 2285, and the approved subdivision plan, were not sufficient to warrant the correction prayed for. The Court cannot accord probative weight to these documents because the public officers who issued them did not testify in court to prove the facts stated therein. As such, sans the testimonies of the issuing public officers to confirm the veracity of the contents, the documents are bereft of probative value and cannot, by their mere issuance, prove the facts stated therein. At best, they may be considered only as prima facie evidence of their due execution and date of issuance but do not constitute prima facie evidence of the facts stated therein. The Court cannot accord probative weight upon them in view of the fact that the public officers who issued the same did not testify in court to prove the facts stated therein. The Court cannot accord probative weight upon them in view of the fact that the public officers who issued the same did not testify in court to prove the facts stated therein. On the issue of whether the documentary evidence possessed sufficient probative value: The Supreme Court ruled that the documentary evidence presented by the respondent lacked sufficient probative value. The Court cited Republic v. Medida and Republic v. T.A.N Properties, Inc., holding that certifications from the DENR cannot be considered prima facie evidence of the facts stated therein unless the issuing officers testify. These certifications are not entries in public records made in the performance of a duty, nor are they certified copies of original official records. Therefore, they do not fall within the class of public documents contemplated in Section 23 of Rule 132 of the Revised Rules on Evidence. Furthermore, the Court noted that the contents of the certifications were hearsay because the respondent's witness was incompetent to testify on their veracity, not having prepared them nor being a public officer of the concerned agencies. Even though the public prosecutor did not object to the admission of this evidence, hearsay evidence, whether objected to or not, has no probative value unless it falls within the exceptions to the hearsay rule, which was not the case here. The absence of opposition from government agencies is also of no controlling significance, as the State cannot be estopped by the omission, mistake, or error of its officials. The burden of proof rests on the plaintiff to rely on the strength of their own evidence, not the weakness of the defendant's.
Main Doctrine
Certifications from DENR officials, without the testimony of the issuing officers, lack probative value to prove the facts stated therein for purposes of correcting a land title. Hearsay evidence, even if admitted without objection, cannot be given credence.