GR 217210; (November, 2016) (Digest)
G.R. No. 217210. November 07, 2016
Republic of the Philippines, Petitioner, v. Capital Resources Corporation, Romeo Roxas, and the Register of Deeds of the Province of La Union, Respondents.
FACTS
The Republic filed a complaint for cancellation of title and reversion over a parcel of land in Bauang, La Union, registered under TCT No. T-23343 in the names of respondents Capital Resources Corporation (CRC) and Romeo Roxas. The property originated from a Homestead Patent granted to Vitaliano Dumuk in 1924, resulting in OCT No. 137. The title was subsequently transferred to spouses Milo and then to the respondents in 1982. A cadastral survey in 1987 and a subsequent DENR investigation revealed that portions of the property, specifically Blocks 35 and 36 of a subdivision plan, were within the foreshore area and seabed. The Republic sought reversion of the entire property to the public domain.
The Regional Trial Court (RTC) ordered the reversion of Blocks 35 and 36 only, declaring them as foreshore land and part of the public domain. It dismissed the complaint regarding the remainder of the property. The Court of Appeals (CA) affirmed this decision. The Republic appealed, contesting only the CA’s affirmation regarding the non-foreshore portion of the land.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s dismissal of the reversion case concerning the remainder of the Subject Property, excluding the declared foreshore lands.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The Court upheld the lower courts’ factual findings, which are generally binding in a Rule 45 petition. The RTC and CA correctly found that the Republic failed to present clear and convincing evidence to overcome the presumption of validity of the respondents’ Torrens title for the remaining portion. The evidence, including the DENR committee’s terminal report, pertained only to the foreshore areas (Blocks 35 and 36), for which reversion was already granted. There was no proof that the rest of the property was similarly inalienable or part of the public domain.
Furthermore, the Court rejected the Republic’s argument that the respondents’ corporate ownership was prohibited. The constitutional prohibition against corporations acquiring alienable lands of the public domain does not apply to private lands. The property became private upon the issuance of the original homestead patent and certificate of title in 1924. Consequently, when CRC acquired it in 1982, it was already private property, and the constitutional restriction was inapplicable. The petition was denied for lack of merit.