Republic v. Court of Appeals

G.R. No. 108926 (July 12, 1996)

Facts:

The case revolves around a property located in Liwanag, Talon (formerly Pamplona), Las Piñas, Rizal, with an area of 45,295 square meters. The property was originally owned by Santos de la Cruz, who declared it under various tax declarations from 1913 to 1921. Over the years, the property changed hands through successive sales and was eventually sold to the petitioner-appellee, Democrito O. Plaza, on July 5, 1966, for P231,340.00. Following the sale, Plaza took possession of the property, paid taxes from 1966 to 1986, and declared it in his name in 1985.

On November 14, 1986, Plaza filed a petition for the registration and confirmation of his title over the property, asserting that he and his predecessors had been in open, continuous, exclusive, and notorious possession of the land since before June 12, 1945. The Republic of the Philippines opposed the petition, arguing that Plaza had not established the requisite possession and that the property was part of the public domain.

The case saw multiple oppositions from other parties, including the Heirs of Santos de la Cruz and the Kadakilaan Estate, who claimed ownership based on historical titles and long-standing possession. The lower court conducted an ocular inspection and later issued a decision confirming Plaza's title, which was subsequently affirmed by the Court of Appeals.

Legal Issues:

1. Whether the petitioner-appellee, Democrito O. Plaza, had established ownership of the property through sufficient evidence of possession and title.
2. Whether the property in question was part of the public domain and thus not subject to private appropriation.
3. The implications of Presidential Proclamation No. 679, which reserved the property for slum improvement and resettlement.

Arguments:

• Petitioner-Appellee (Plaza):

  • Plaza argued that he had validly acquired the property through a deed of sale and had been in continuous possession since 1966, supported by tax declarations and payment receipts.
  • He contended that the evidence of possession was sufficient to establish ownership, as he had declared the property for taxation and paid the corresponding taxes.

• Respondent (Republic of the Philippines):

  • The Republic maintained that Plaza and his predecessors had not been in the required open, continuous, exclusive, and notorious possession since June 12, 1945.
  • It argued that the tax declarations and payments were insufficient to prove ownership and that the property was part of the public domain, thus not subject to private appropriation.
  • The Republic also cited Presidential Proclamation No. 679, asserting that it withdrew the property from sale or settlement, which should affect the registration of title.

Court's Decision and Legal Reasoning:

The Court of Appeals affirmed the lower court's decision, finding that Plaza had proven his claim of ownership through substantial evidence, including historical tax declarations and proof of payment. The court emphasized that tax declarations, while not conclusive evidence of ownership, are strong indicia of possession in the concept of ownership. The court noted that Plaza's predecessors had declared the property for taxation since 1923, indicating long-standing possession.

Regarding the Republic's claim that the property was part of the public domain, the court ruled that the issuance of Proclamation No. 679 did not negate Plaza's ownership. The proclamation reserved the land for slum improvement but acknowledged existing private rights, meaning that if Plaza could prove ownership, he was entitled to have the land titled in his name.

The court reiterated that registration does not confer title but merely confirms it. The law recognizes that a person who has possessed land in the concept of ownership for a sufficient period may acquire rights to it, independent of the state’s claims.

Significant Legal Principles Established:

1. Possession as Evidence of Ownership: Continuous, open, and notorious possession, coupled with tax declarations and payments, can establish a claim of ownership over property.
2. Public Domain and Private Rights: Even if land is reserved for public use, existing private rights must be respected, and ownership claims can still be validated through legal processes.
3. Registration of Title: The act of registering land does not confer ownership but serves as evidence of the title one already possesses.