Republic v. Manahan-Jazmines, G.R. No. 227388, JULY 23, 2018 - Synopsis only
Republic of the Philippines
v.
Maria Theresa Manahan-Jazmines,
G.R. No. 227388, JULY 23, 2018
Full text:
Ponente: GESMUNDO, J.:
Short Facts:
In 2009, a respondent filed an application for registration of four parcels of land under the Property Registration Decree. The respondent claimed to have inherited the land from her parents and that she and her predecessors-in-interest had occupied the land for over 40 years, solely for agricultural purposes. The RTC granted the application, but the Republic appealed to the CA, arguing that the RTC erred. The CA affirmed the RTC ruling, but the Republic appealed to the Supreme Court. The Supreme Court held that the respondent had failed to prove open, continuous, exclusive and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945 or earlier, as required by law. The respondent's application for registration of the land was therefore denied.
Synopsis:
On March 11, 2009, a respondent filed an application for the registration of four parcels of land under Presidential Decree (P.D.) No. 1529 or the Property Registration Decree. The lots were situated in Brgy. San Rafael, Rodriguez, Rizal and had been declared for taxation purposes. The respondent claimed ownership of the lots by inheritance from her parents and asserted that she, along with her predecessors-in-interest, had occupied the subject lots for over forty years, devoting the land solely for agricultural purposes.
The respondent presented evidence in the form of a certification from CENRO classifying the lands as alienable and disposable, an affidavit of self-adjudication, and an approved survey plan. The RTC granted the respondent's application, noting that she had duly established the ownership of her predecessors-in-interest and her continued possession of the lots through tax declarations. The CA later affirmed the RTC ruling, finding that the notice and publication of the initial hearing was sufficient for the court to acquire jurisdiction and that the lots were alienable and disposable.
However, the Republic appealed to the Supreme Court, arguing that the respondent had failed to prove open, continuous, exclusive, and notorious possession of the lots under a bona fide claim of ownership since June 12, 1945, or earlier, as required by P.D. 1529 and C.A. 141.
The Supreme Court ultimately agreed with the Republic, reversing the ruling of the CA. The Court held that the respondent had not presented incontrovertible evidence of open, continuous, exclusive, and notorious possession of the lots since June 12, 1945, or earlier. Additionally, the tax declarations presented only dated back to 1965, and there was no evidence that the respondent or her predecessors-in-interest had continuously cultivated the land.
The decision serves as a reminder that applications for the registration of imperfect titles must comply with the requirements set forth in P.D. 1529 and C.A. 141. Applicants must prove open, continuous, exclusive, and notorious possession of the land under a bona fide claim of ownership since June 12, 1945, or earlier, through incontrovertible evidence. Tax declarations alone may not be sufficient to prove ownership, but they can serve as a basis for inferring possession.
In conclusion, the Supreme Court denied the respondent's application for the registration of the subject lots under P.D. No. 1529, emphasizing the importance of meeting the requirements for the registration of imperfect titles. This case serves as a reminder to applicants for the registration of land titles to provide sufficient and incontrovertible evidence of possession and ownership to support their claims.
Nature of petition:
This is an appeal by certiorari seeking to reverse and set aside the Decision dated March 15, 2016 and Resolution dated September 20, 2016 of the Court of Appeals (CA) in CA-G.R. CV No. 99962. The CA affirmed the Decision of the Regional Trial Court of San Mateo, Rizal, Branch 75 (RTC) dated October 5, 2012, granting the application of registration of title in LRC Case No. N-330-09 SM, filed by Maria Theresa Manahan-Jazmines (respondent).
Dispositive portion:
WHEREFORE, the petition is GRANTED. The Decision dated March 15, 2016, and Resolution dated September 20, 2016, of the Court of Appeals in CA-G.R. CV No. 99962 are REVERSED and SET ASIDE. The application for registration filed by Maria Theresa Manahan-Jazmines before the Regional Trial Court of San Mateo, Rizal, Branch 75 in LRC Case No. N- 330 09 SM is hereby DENIED.