G.R. No. 158919 . August 9, 2005.
Republic of the Philippines and Cavite College of Fisheries, Petitioners, vs. Maxima Lensico, Rufina Lensico, Rogelio Lensico and Victor Lensico, Respondents.

FACTS

The case involves a parcel of land originally part of the Friar Lands Estate in Naic, Cavite. The deceased Melanio Lensico, after occupying the land for 34 years, filed an Application to Purchase Friar Lands in 1964. After investigation and approval, a Sales Contract was executed, and Transfer Certificate of Title No. T-78832 was eventually issued in 1975 in the names of Melanio Lensico and his spouse. Their heirs, the respondents Lensicos, discovered that the Cavite College of Fisheries (CCF) was occupying a significant portion of the titled property. After demands for compensation were ignored, the Lensicos filed a suit for recovery of possession.
The Republic of the Philippines and CCF contested the title. They argued the land was part of the foreshore, a public domain, and thus inalienable. They claimed R.A. No. 2661 , enacted in 1960, had already designated the area for the school’s establishment, and that CCF’s occupation since 1961, including the construction of valuable improvements like rock groins and buildings, gave it a superior right. The Republic also filed a separate suit for annulment of title and reversion, alleging fraud in the sales application for failing to disclose the school’s improvements.

ISSUE

The core issue is whether the Supreme Court can overturn the factual findings of the lower courts, which upheld the validity of the Lensicos’ title and their right to recover possession or be compensated.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court emphasized that in a Rule 45 petition, it is not a trier of facts. Its jurisdiction is limited to reviewing errors of law, not re-examining factual determinations, absent any showing that the findings are devoid of support or are based on a misapprehension of facts. The trial court and the CA found that the land was not foreshore but a friar land, an alienable public agricultural land, which Melanio Lensico validly purchased. The Republic and CCF failed to present clear and convincing evidence to overcome the presumption of regularity in the issuance of the title or to prove that the land was indeed foreshore at the time of the sale.
The Court found no merit in the claim of fraud, as the alleged non-disclosure of CCF’s buildings was not sufficiently proven to have vitiated the contract. The existence of R.A. No. 2661 did not automatically convert the property to public use or nullify a prior perfected sale of alienable land. The determination of just compensation for CCF’s occupancy, being a factual matter, was also upheld. Consequently, the Lensicos’ rights as registered owners were sustained.