G.R. No. 256194 , January 31, 2024
Republic of the Philippines, Petitioner, vs. Heirs of Rogelio P. Laudes, represented by Victoria Ordiz Vda. de Laudes, Respondents.

FACTS

The respondents, Heirs of Rogelio Laudes, acquired two parcels of land in Paracale, Camarines Norte, through a sheriff’s sale in 1990. The sale satisfied a civil liability judgment against Jesus Enova, whose properties were levied. A Sheriff’s Final Deed was issued in 1991. Despite a writ of possession, the Heirs faced challenges in securing physical possession due to third-party claims. In a related civil case for recovery of property, the RTC declared the Heirs as the true and lawful owners of the subject properties in an Order dated January 5, 2000.
Subsequently, the Heirs filed applications for original registration of the lands. The cases were consolidated before the RTC, which granted registration. The court found the Heirs proved the lands were alienable and disposable, and that they and their predecessor-in-interest, Jesus Enova, had possessed the lands openly, continuously, exclusively, and notoriously since June 12, 1945, or earlier. The Court of Appeals affirmed this decision. The Republic, through the Office of the Solicitor General, elevated the case, arguing the Heirs failed to prove the requisite possession and the alienable status of the lands.

ISSUE

Whether the respondents have sufficiently established their right to original registration of the subject properties under Section 14(1) of Presidential Decree No. 1529.

RULING

The Supreme Court denied the petition and affirmed the registration. The Court held that the respondents successfully proved all requisites for judicial confirmation of imperfect title. First, the certifications from the DENR-CENRO, which were issued pursuant to a valid delegation of authority from the DENR Secretary, constituted sufficient evidence that the lands were classified as alienable and disposable as early as July 18, 1941. These public documents enjoy the presumption of regularity.
Second, the Court found the evidence of possession and occupation to be clear and convincing. The Heirs presented tax declarations and receipts in the name of their predecessor, Jesus Enova, dating back to 1948. More critically, the testimony of witness Teofilo Oco, who was 92 years old at the time of trial, established that his father had purchased the land from Enova in 1945 and that Enova had already been in possession long before that sale. This unrebutted testimony provided the necessary factual basis for the conclusion of possession since June 12, 1945, or earlier. The possession, which was open, continuous, exclusive, and notorious, was tacked to the Heirs from their predecessor-in-interest. The Court emphasized that factual findings of the trial court, when affirmed by the CA, are generally binding unless shown to be grounded on speculations. No such error was demonstrated here. Thus, the Heirs of Laudes have acquired an imperfect title worthy of judicial confirmation.