GR L 9064; (March, 1915) (Digest)
G.R. No. L-9064; March 31, 1915
THE ROMAN CATHOLIC ARCHBISHOP OF MANILA, applicant-appellant, vs. MACARIO ARNEDO, ET AL., objectors-appellees.
FACTS:
The Roman Catholic Archbishop of Manila, a corporation sole, filed an application with the Court of Land Registration for the inscription of three parcels of land with a total area of 506,521 square meters, located in the barrios of San Isidro and San Vicente of Macabebe and Apalit, Pampanga. The applicant claimed ownership by virtue of a donation originating from a mission founded in 1724 by Melchor Mallari, which was endowed with 40 quiñones of land in the sitio of Caputatan, Macabebe.
The application was opposed by Macario Arnedo and his siblings, and separately by Pelagio Nunga. The Arnedos claimed ownership by hereditary title from their father, Joaquin Arnedo, who had possessed the lands since 1858. They had inscribed their ownership and possession in the property registry. Pelagio Nunga claimed ownership of two parcels within the application, acquired by his mother through a title of composition with the state.
The trial court denied the application for inscription. It found that the lands were not sufficiently identified in the applicant’s documents, as there were multiple places named Caputatan in the area. The court also found that the oppositors had been in public, peaceful, and continuous possession of the lands under a claim of ownership for more than thirty years.
ISSUE:
Whether the applicant, the Roman Catholic Archbishop of Manila, has sufficiently proven its ownership and the identity of the lands it seeks to inscribe, such that its application for registration should be granted.
RULING:
No. The Supreme Court affirmed the denial of the application for registration.
The Court held that an applicant for land registration, like a plaintiff in a recovery suit, must prove by satisfactory and conclusive evidence both its ownership and the specific identity of the land. The applicant failed on both counts.
First, the applicant failed to sufficiently identify the lands. The documentary evidence only indicated lands in “Caputatan,” but the oppositors proved there were multiple sitios with that name in the municipality. Furthermore, the lands described in the application were in the barrios of San Isidro and San Vicente, while the lands actually possessed by the oppositors were in the barrio of San Gabrieldistinct and different locations.
Second, the applicant failed to prove a superior title of ownership. The evidence for the mission’s foundation was vague. It did not precisely show the location, metes, and bounds of the original 40 quiñones. By 1858, a descendant of the founder reported the land had been reduced to only 4 quiñones. The attempt in 1859 to take possession of the full 40 quiñones was met with immediate protest.
In contrast, the oppositors proved their valid and longstanding ownership. The Arnedos presented possessory information titles, which, having been inscribed for over the required period, constituted prima facie evidence of ownership. Their possession, tacked with their predecessor’s, extended for more than twenty and even fifty years in some parcels. Pelagio Nunga held a title of composition with the state, which is a title of exclusive ownership, and there was no proof that his lands were part of the mission’s original endowment.
Therefore, the applicant did not overcome the oppositors’ evidenced titles and possession. The judgment denying the application was affirmed.
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