GR 215009; (January, 2017) (Digest)
G.R. No. 215009, January 23, 2017
Republic of the Philippines, Petitioner, vs. Carmen Santorio Galeno, Respondent.
FACTS
Respondent Carmen Santorio Galeno, a co-owner of Lot No. 2285 covered by Original Certificate of Title (OCT) No. 46417, filed a petition for correction of the land area stated in the title before the Regional Trial Court (RTC). She alleged that a resurvey for partition revealed a discrepancy: the title indicated an area of 20,948 square meters, while a Certification from the DENR’s Land Management Services stated the area as 21,298 square meters. The RTC granted the petition, finding the jurisdictional requirement of notice to adjoining owners satisfied and the evidence sufficient. The Court of Appeals affirmed, noting no objection from adjoining owners and a lack of contrary evidence from the Republic.
ISSUE
Whether the Court of Appeals erred in upholding the correction of the land area in OCT No. 46417.
RULING
The Supreme Court granted the petition and reversed the lower courts. The legal logic centers on the insufficiency of the respondent’s evidence to warrant a correction under the rules. The respondent relied on a DENR Certification and related documents to prove the alleged true area. However, these documents, though public in form, were not afforded probative value because the public officers who issued them did not testify in court to authenticate the facts stated therein. Following Republic v. Medida, such certifications cannot be considered prima facie evidence of the facts contained unless the issuing officers are presented to testify, as they constitute hearsay if not properly attested to in court.
The burden of proof lies with the party seeking the correction. The respondent failed to present competent, admissible evidence to establish by preponderance that the true area was 21,298 square meters. The absence of opposition from adjoining owners does not relieve the respondent of this burden or cure the evidentiary defect. Consequently, the petition for correction lacked merit and was properly dismissed. The ruling reinforces strict adherence to the rules of evidence in proceedings affecting the integrity of Torrens titles.