Case Digest on Natural Resources Law
San Miguel Corporation vs. Court of Appeals
Facts: A petition for review on certiorari was filed by San Miguel Corporation (SMC) against Court of Appeals for denying its application for registration of a parcel of land located at Sta. Anastacia, Sto. Tomas, Batangas with lot number 684 with an area of 14,531 square meters. The lot was purchased by SMC from Silverio Perez in the amount of Php 133,084.80 on December 23, 1975. Accordingly he inherited the land from his parents when he got married. Allegedly, his parents occupied the said area since 1925. On February 21, 1977 claiming ownership in Fee Simple of the land, SMC filed before the Court of First Instance now Regional Trial Court of Batangas an application for registration under the Land Registration Act. The Solicitor General contended that ownership in Fee Simple on the basis of Spanish Title or grant could no longer be availed for the sixth-month period, from February 16, 1976 prescribed by P.D. 892 has elapsed, so the parcel of land in question is a public domain. On October 12, 1977 an initial and only hearing was conducted wherein SMC was allowed to mark documentary evidence and to establish documentary facts and to prevent additional evidence. On December 12, 1977 the lower court granted the application for registration and adjudicating the property to SMC. The Solicitor General appealed the decision of the lower court to the Court of Appeals which reversed the decision of the lower court and declared the land involved as public land. Hence, SMC appealed the decision of the Court of Appeals to the Supreme Court and allegedly the Court of Appeals committed grave errors: 1.
A failure to hold the prescription is a mode of acquiring title or ownership of land and the title thus acquired id registrable. 2.
CA disregards SMC’s evidence
CA reversal of the factual findings of the trial court which had the opportunity of observing the demeanor and sincerity of the witnesses.
Issue: Whether or not the lot purchased by SMC is a public land.
Held: The Supreme Court held that “Open, exclusive and undisputed possession of alienable public land for the period prescribed by law creates the legal fiction whereby the land, upon completion of the requisite period and without the need of judicial sanction, ceases to be public land and becomes private property”. In the case at bar the only evidence presented was a tax declaration and receipt which are not conclusive evidence of the ownership or a right possession of the land. The testimony of the vendor Silverio Perez was uncorroborated hence is simply self-serving and undeserving of any weight, hence the decision of the Court of Appeals was affirmed by the Supreme Court.
Hong Hok vs. David
Facts: This is a petition for certiorari from the Court of Appeals which affirms the decision of the lower court, to grant the Torrens Title to respondent Aniano David, which was greatly opposed by the plaintiff-appellant. The plaintiff-appellant claiming is ownership to the Naga cadastre with lot number 2863, a portion of which is the source of the disputed lot 2892 containing an area of 226 square meters. This lot was occupied by the wife of Aniano David since 1938. The respondent’s wife applied for registration of the said lot, unfortunately she died respondent renewed the application. On June 18 1958 the respondents acquired a lawful title grant from the government represented by the Director of Lands, on this basis the undersecretary of Agriculture and Natural Resources issued on August 26, 1959 a miscellaneous Sales Patent no. V-1209 pursuant to which an OCT No. 510 was issued by the Register of Deeds of Naga City to the defendant on October 21, 1959. The auction sale of land and the awarding of the land to the defendant were all done publicly but the plaintiff-appellant failed to put up an opposition thereto. They rely on their theory that the said lot came into being...
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