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REPUBLIC v. BANTIGUE POINT DEVELOPMENT CORPORATION

FACTS:

Respondent Bantigue Point Development Corporation filed an application for original registration of title over a parcel of land with the Regional Trial Court (RTC) of Rosario, Batangas. However, the RTC transferred the case to the Municipal Trial Court (MTC) of San Juan due to the property's assessed value being less than P100,000. The MTC entered an Order of General Default and proceeded with the reception of evidence. The MTC granted the application for registration and awarded the land to the respondent Corporation. The Republic of the Philippines, dissatisfied with the decision, filed a Rule 45 Petition and raised arguments questioning the jurisdiction of the MTC over the application.

ISSUES:

  1. Whether the Republic of the Philippines (Republic) can be estopped from questioning the jurisdiction of the Municipal Trial Court (MTC) over the application for original registration of land title even for the first time on appeal.

  2. Whether the Municipal Trial Court (MTC) properly acquired jurisdiction over the application for original registration of land title.

RULING:

  1. The Republic is not estopped from raising the issue of jurisdiction. The rule is settled that lack of jurisdiction over the subject matter may be raised at any stage of the proceedings.

  2. The Municipal Trial Court (MTC) properly acquired jurisdiction over the case. The assessed value of the property did not exceed P100,000, which falls under the MTC's delegated jurisdiction. However, the case must be remanded for further proceedings to determine if the property forms part of the alienable and disposable land of the public domain.

PRINCIPLES:

  1. Estoppel by Laches: A party can be precluded from raising the question of lack of jurisdiction on appeal if they have actively participated in the proceedings at the lower court and only later raised the jurisdictional question after an adverse decision. However, this is an exception and not the general rule.

  2. Jurisdiction Over Subject Matter: Jurisdiction over the subject matter is conferred only by the Constitution or the law and cannot be acquired through waiver, omission, or acquiescence.

  3. MTC Delegated Jurisdiction: The Municipal Trial Court has delegated jurisdiction over cadastral and land registration cases if the value of the lot does not exceed P100,000, as determined by tax declaration, affidavit of the claimant, or agreement among claimants.

  4. Regalian Doctrine: All lands of the public domain belong to the State. To overcome this presumption, the applicant for land registration must provide incontrovertible evidence of the land's alienable and disposable status based on a positive act of the government.

  5. Requirements for Original Land Registration: A CENRO or PENRO certification is insufficient; applicants must also present a copy of the original land classification approved by the DENR Secretary and certified as a true copy by the custodian of the official records.