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REPUBLIC v. TRI-PLUS CORPORATION

FACTS:

This case involves an application for registration of title initiated by Tri-Plus Corporation, seeking to register two parcels of land in Consolacion, Cebu. Tri-Plus Corporation claimed ownership of the subject properties through purchase and alleged that they have been in actual, continuous, public, notorious, exclusive, and peaceful possession for more than 30 years. The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed the application, arguing that Tri-Plus Corporation failed to prove open, continuous, exclusive, and notorious possession since June 12, 1945. The OSG also contended that the tax declarations and receipts submitted by Tri-Plus Corporation were insufficient evidence of ownership and claimed that the subject lands were part of the public domain. The heirs of Toribio Pepito had expressed intention to oppose the application but failed to do so within the given period.

During the proceedings, the trial court received documentary evidence from Tri-Plus Corporation and appointed a commissioner to receive evidence. The commissioner submitted a report on the proceedings. Eventually, the trial court issued a judgment declaring Tri-Plus Corporation as the exclusive and absolute owner of the subject lots. The OSG appealed the decision to the Court of Appeals (CA).

Meanwhile, the Land Registration Authority (LRA) submitted a report highlighting a discrepancy in the boundaries of Lot 1061 and an adjoining lot. The LRA expressed uncertainty regarding whether the subject lands were already covered by a land patent.

The CA affirmed the trial court's decision. The petitioner in this case raised three assigned errors. First, they contended that there was uncertainty regarding the identity of Lot 1061. Second, they argued that Tri-Plus Corporation failed to prove the alienability and disposability of the properties. Finally, they asserted that the applicant was disqualified from acquiring public domain lands. The respondent countered these arguments by stating that the identity of Lot 1061 was proven with certainty, the notations in the survey plans were sufficient evidence of alienability, and that Tri-Plus Corporation's continuous possession as the predecessor-in-interest was that of an owner.

ISSUES:

  1. Whether the identity of Lot 1061 was properly established.

  2. Whether the discrepancy in the common boundary between Lot 1061 and Lot 1058 affects the identity of Lot 1061.

  3. Whether the MTC should have dismissed the application for registration based on the LRA Report.

  4. Whether respondent has complied with the legal requirements for the application for registration.

  5. Whether the subject lands are alienable and disposable public lands.

  6. Whether there is sufficient evidence to establish open, continuous, exclusive, and notorious possession by the respondent and its predecessors-in-interest since June 12, 1945 or earlier.

  7. Whether or not the respondent Tri-Plus Corporation is entitled to the registration and issuance of titles for Lots 1061 and 1062, Consolacion Cad-545-D.

  8. Whether or not the strict safeguards relative to the registration of imperfect titles should be relaxed.

RULING:

  1. The Court finds respondent's submission of a blueprint copy of the Advance Plan of Lot 1061 and a Technical Description thereof as substantial compliance with the legal requirements for the proper identification of Lot 1061.

  2. The discrepancy in the common boundary between Lot 1061 and Lot 1058 does not cast doubt on the identity of Lot 1061 because it does not unduly increase or affect the total area of the subject lot. Only a portion of the boundaries of Lot 1061 bears a discrepancy and the LRA Report recommends verification and correction, if necessary, to avoid duplication of titles.

  3. The MTC could not have dismissed the application for registration based on the LRA Report because it was submitted to the trial court after the MTC rendered its Decision. By the time the LRA report was submitted, the MTC had already lost jurisdiction over the case due to the appellate court acquiring jurisdiction through the timely filing of an appeal.

  4. Respondent failed to prove that the properties sought to be titled form part of the alienable and disposable agricultural lands of the public domain. Thus, respondent did not comply with the legal requirements for the application for registration.

  5. The respondent failed to present proper evidence to prove that the subject lands are alienable and disposable public lands. The notation in the Advance Plan stating that the properties are alienable and disposable is not sufficient to establish their character. The respondent did not provide a certification from the proper government agency to prove their status.

  6. The respondent and its predecessors-in-interest failed to prove their open, continuous, exclusive, and notorious possession of the subject lands since June 12, 1945 or earlier. The testimonial evidence and documentary evidence, such as tax declarations, presented were inadequate to establish such possession.

  7. The Supreme Court granted the petition and reversed the decision of the Court of Appeals. The application for registration and issuance of title for Lots 1061 and 1062, Consolacion Cad-545-D, filed by the respondent Tri-Plus Corporation, was dismissed.

PRINCIPLES:

  • The submission of the original tracing cloth plan is a mandatory requirement to establish the true identity of the land in an application for registration. However, other evidence such as blueprint copies can also provide sufficient identification. (Republic of the Philippines v. Court of Appeals, Spouses Recto v. Republic of the Philippines, Republic of the Philippines v. Hubilla)

  • Discrepancies in boundaries do not affect the identity of a lot if they do not unduly increase or affect the total area of the subject lot and do not prejudice the adjoining lot owner. (LRA Report)

  • The MTC loses jurisdiction over a case once an appeal has been timely filed, regardless of the submission of subsequent reports or documents.

  • The classification and reclassification of public lands into alienable or disposable, mineral or forest land is the prerogative of the Executive Department. In the absence of evidence of reclassification or release, public lands remain part of the inalienable public domain.

  • The burden of proof in land registration cases rests on the applicant, who must show clear, positive, and convincing evidence of possession and occupation that meets the legal requirements.

  • A mere notation in an Advance Plan stating that the land is alienable and disposable is not sufficient evidence to establish its character. The applicant must present a positive act of the government, such as a presidential proclamation, executive order, administrative action, investigation reports, legislative act, or certification.

  • The law imposes stringent safeguards upon the registration of imperfect titles to ensure the preservation of the national patrimony.

  • The Court must not relax the rigorous standards in granting registration and issuance of titles for land resources.