G.R. No. 180218 December 18, 2009
REPUBLIC OF THE PHILIPPINES, Petitioner, vs. DEVELOPMENT RESOURCES CORPORATION, represented by Carlos Chua and THE REGISTER OF DEEDS OF DAVAO CITY, Respondents.

FACTS

On October 14, 1922, the Court of First Instance of Davao, sitting as a cadastral court, adjudicated Lot 544 of Cad-102 in Davao City in favor of Antonio Matute. Original Certificate of Title (OCT) 493 was issued to Matute on December 15, 1925. Subsequent transfer certificates of title (TCTs) were derived from this OCT, including TCT 44671 and TCT 44675, both in the name of respondent Development Resources Corporation (DRC). On April 5, 1993, the Republic of the Philippines, through the Office of the Solicitor General, filed a complaint for cancellation of these TCTs and reversion of the corresponding lots to the public domain. The Republic claimed that Lot 544 was still a public forest and inalienable on the date of its adjudication to Matute (October 14, 1922), and was only declared alienable on August 6, 1923, based on Land Classification (LC) Map 47. The Republic presented a DENR certification to this effect. DRC contended the lots were now private property held by purchasers in good faith. The Regional Trial Court (RTC) dismissed the complaint, ruling the Republic failed to prove the lots were part of the public domain when adjudicated, noting LC Map 47 had no probative value as it was a non-certified reproduction and did not explicitly state the land became alienable only on August 6, 1923. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether or not respondent DRC’s titles over the subject lots can be cancelled, having been supposedly issued when, based on LC Map 47, these lots were still inalienable lands of the public domain.

RULING

The Supreme Court DENIED the petition and upheld the dismissal of the reversion suit. The Court ruled that the Republic failed to discharge its heavy burden of proof in a reversion case that seeks to upset registered titles. First, the Republic failed to present the original or a certified true copy of LC Map 47, offering only an electronic reproduction which has no probative value. A mere photocopy or reproduction is not competent evidence unless it is a certified copy issued by the public officer having custody of the original. Second, LC Map 47 did not conclusively state that Lot 544 became alienable and disposable only on August 6, 1923; the date on the map merely indicated when it was certified. The DENR certification offered had no additional value as it was based on the same map. The Court cited precedent (Sta. Monica Industrial and Development Corporation v. Court of Appeals) that such a map does not conclusively prove the land’s classification at the time of its adjudication. Therefore, the courts below correctly dismissed the suit for the Republic’s failure to meet its evidential burden.