G.R. No. 172931 , June 18, 2009
REPUBLIC OF THE PHILIPPINES, represented by the DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES (DENR), Petitioner, vs. REGIONAL TRIAL COURT, BRANCH 18, ROXAS CITY, CAPIZ, RIZAL RECIO, TERESITA RECIO, PACIENCIA RECIO, and HEIR OF OSCAR RECIO, HARRIET VILLANUEVA vda. DE RECIO, and the REGISTER OF DEEDS, ROXAS CITY, CAPIZ, Respondents.

FACTS

On September 14, 1984, the Regional Trial Court (RTC) of Roxas City, Branch 18, rendered a decision in Land Registration Case (LRC) No. N-785, granting the application for registration of title filed by Rizal Recio for himself and on behalf of his siblings over Lot No. 900 of the Pilar Cadastre. The RTC ordered the confirmation and registration of title in the names of the applicants. The decision became final, and Original Certificate of Title (OCT) No. 0-2107 was issued on April 17, 1985. In 1997, occupants of the lot filed a protest with the DENR, alleging the land was within forest lands or timberlands and thus inalienable. A DENR Special Investigator, Lorna L. Jomento, conducted an investigation and reported that Lot No. 900 fell within forest lands reserved for fishpond purposes under Project No. 20-A, established in 1986 per Land Classification Map No. 3132, and recommended court action for cancellation of the title. On September 9, 2002, the Republic, represented by the DENR through the Office of the Solicitor General, filed a petition for annulment of judgment before the Court of Appeals, arguing the RTC had no jurisdiction to adjudicate title over forest land, which is not alienable and disposable. The Recios countered that the RTC had jurisdiction, presenting a 1976 certification from the then Bureau of Forest Development stating the lot was within alienable and disposable land Block LC Project No. 20, and argued the case was closed and res judicata had set in. The Court of Appeals dismissed the petition, finding the Republic failed to sufficiently prove its allegation that the lot was forest land, as it only presented witness testimonies, Jomento’s written report, and an inadmissible photocopy of a sketch plan, while the Recios presented a certification of alienability.

ISSUE

1. Did the RTC act without jurisdiction in allowing the registration of the subject land?
2. Did the petitioner fail to discharge the burden of establishing the inalienable character of the land?

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision.
1. On Jurisdiction: The Court ruled that the RTC had jurisdiction over the application for registration. Jurisdiction is conferred by law and determined by the allegations in the application. The application alleged the land was alienable and disposable, which was within the RTC’s jurisdiction under Section 14 of Presidential Decree No. 1529. Any error in its decision, such as a possible mistaken finding of alienability, would be an error in the exercise of jurisdiction, not a lack of jurisdiction. A judgment rendered by a court with jurisdiction is not void and can only be corrected through a timely appeal, not annulment.
2. On Burden of Proof: The Court held that the petitioner failed to discharge its burden of proving the land was inalienable forest land. The quantum of proof required in civil cases is preponderance of evidence. The petitioner’s evidence—testimonies of two witnesses, Jomento’s report, and a photocopy of a sketch plan—was insufficient. The photocopy was inadmissible under the best evidence rule. The testimonies and report, which stated the lot was within Project 20-A (a 1986 classification), did not overcome the Recios’ evidence: a 1976 certification from the Bureau of Forest Development (a predecessor of the petitioner DENR) explicitly certifying that Lot No. 900 was within alienable and disposable Block LC Project No. 20, certified as such in 1960. The petitioner did not present the actual Land Classification Map No. 3132 to substantiate its claim. Consequently, the petitioner did not prove its allegation that the land was inalienable, and the annulment of judgment was properly dismissed.