GR 160421; (October, 2004) (Digest)
G.R. No. 160421 ; October 4, 2004
SPOUSES PHILIP RECTO and ESTER C. RECTO, represented by their Attorney-in-fact, GENEROSO R. GENEROSO, petitioners, vs. REPUBLIC OF THE PHILIPPINES, respondent.
FACTS
Petitioners Spouses Recto applied for registration of title over a 23,209-square-meter lot in Batangas under P.D. No. 1529. They claimed ownership through purchase from the Medrana sisters, who inherited it from their father, Vicente Medrana. The Medranas allegedly possessed the land in the concept of owners since before 1945, cultivating it with rice and corn. Petitioners presented numerous documents, including tax declarations dating back to 1948, and certifications from the DENR stating the land was within an alienable and disposable zone classified under Project No. 30 per LC Map No. 582 certified on December 31, 1925.
The Regional Trial Court granted the application. The Republic appealed, arguing petitioners failed to present the original tracing cloth plan, prove possession since June 12, 1945, and overcome the presumption that the land is public domain. The Court of Appeals reversed the RTC decision solely on the ground of petitioners’ failure to submit the original tracing cloth plan as evidence. Petitioners moved for reconsideration, seeking a remand to present the plan, which the Solicitor General did not oppose, but the CA denied the motion.
ISSUE
Whether the Court of Appeals erred in reversing the RTC’s grant of land registration based solely on the non-submission of the original tracing cloth plan.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the RTC decision. The legal logic is that the submission of the original tracing cloth plan is a mandatory requirement in original land registration proceedings to establish the true identity of the land and prevent duplication. However, this requirement admits of exceptions. The Court found that petitioners substantially complied with this requirement by submitting a blueprint copy of the plan and its technical description, both duly certified by the Land Management Services of the DENR. These documents sufficiently identified the land.
Moreover, the Court held that petitioners successfully proved all the requisites for registration under Section 14(1) of P.D. No. 1529. The DENR certifications conclusively established that the land was classified as alienable and disposable as early as December 31, 1925. The testimonial and documentary evidence, including tax declarations from 1948, proved open, continuous, exclusive, and notorious possession and occupation by petitioners and their predecessors-in-interest under a bona fide claim of ownership since June 12, 1945, or earlier. The Solicitor General’s non-opposition to the petition further bolstered the merits of the case. Therefore, technicality should not prevail over substantive rights, and registration was properly granted.