G.R. No. 119288 August 18, 1997
REPUBLIC OF THE PHILIPPINES, represented by THE DIRECTOR OF LANDS, petitioner, vs. HON. COURT OF APPEALS and JOSEFA GACOT, respondents.

FACTS

The Republic, through the Director of Lands, sought the annulment of a Court of Appeals decision affirming the Regional Trial Court’s adjudication of Lot No. 5367 in Palawan to the late Josefa Gacot. Gacot had filed an answer in Cadastral Case No. 13, claiming ownership through purchase in 1955 and alleging over 30 years of open, continuous possession. The trial court awarded her the lot in 1990. During the Republic’s appeal, the Solicitor General discovered a 1950 decision by Judge Lorenzo Garlitos declaring Lot No. 5367, among others, as property of the Republic following a general default in the cadastral proceedings. The appellate court remanded the case to the trial court to allow the Republic to present this newly found 1950 decision.
Upon remand, the government’s counsel failed to present any evidence or memorandum to support its claim, despite several hearings. The trial court, in a 1993 decision, reaffirmed its award to Gacot, noting the government’s failure to object during hearings and its acceptance of her tax payments. The Court of Appeals affirmed this ruling, prompting the Republic’s petition to the Supreme Court, arguing the 1950 decision rendered the lot public land and Gacot’s subsequent claim time-barred.

ISSUE

Whether the Court of Appeals erred in affirming the award of Lot No. 5367 to Josefa Gacot despite the existence of a 1950 cadastral decision declaring it property of the Republic.

RULING

The Supreme Court granted the petition and remanded the case to the trial court for further proceedings. The Court held that the 1950 decision of Judge Garlitos was a vital piece of evidence that fundamentally altered the case’s context. This decision, being a public record and a prior judicial act of the same court in the same cadastral proceeding, was a proper subject of judicial notice. Its existence meant Lot No. 5367 had been previously declared public domain, placing the burden on Gacot to prove a superior right, potentially through a subsequent confirmation of imperfect title under relevant laws.
The trial court’s reaffirmation of its award, based solely on the government’s procedural lapses during the rehearing, was erroneous. The government’s failure to formally present the 1950 decision did not negate its legal effect, as courts may take judicial notice of their own records. The core issue required a resolution of the conflicting claims in light of this decisive document. Furthermore, the Court noted the need to ascertain the exact area claimed, as records indicated a portion of the lot might be classified as timberland or part of a forest reserve, which is generally inalienable. Thus, a remand was necessary for the trial court to properly evaluate all evidence, including the 1950 decision and the lot’s classification, to achieve a just and definitive resolution.