Manzana vs. Republic

R.A. No. 11573, which amended Section 14 of P.D. No. 1529 by shortening the required period of adverse possession for judicial confirmation of title from "June 12, 1945 or earlier" to "at least twenty (20) years immediately preceding the filing of the application for confirmation of title," applies retroactively to all applications for judicial confirmation of title pending as of September 1, 2021, including those before the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts exercising delegated jurisdiction in land registration cases, and those pending before the Supreme Court.

Spouses Dante and Sonia Manzana acquired a 2,815-square meter parcel of land designated as Lot 5653, Psc-16, Morong Cadastral, in Barangay San Juan, Morong, Rizal, from Caridad Bonifacio by way of a Deed of Sale in April 1990. They sought original registration of title over the property under P.D. No. 1529, the Property Registration Decree. The Republic, through the Office of the Solicitor General, opposed the application on the ground that the property remained part of the public domain and that the spouses had not satisfied the possession requirements under the law. During the pendency of the petition before the Supreme Court, R.A. No. 11573 was enacted on July 16, 2021 and took effect on September 1, 2021, amending the period of possession required for judicial confirmation of title and prescribing new proof of land classification status.

On September 10, 2002, spouses Dante and Sonia Manzana filed before the Municipal Trial Court of Morong, Rizal, acting as a Land Registration Court, an Application for original registration of land under P.D. No. 1529. They alleged ownership of a 2,815-square meter parcel of land designated as Lot 5653, Psc-16, Morong Cadastral, situated in Barangay San Juan, Morong, Rizal, with an assessed value of ₱6,640.00 under Tax Declaration No. 02-2339-A. They asserted that they acquired the land from Caridad Bonifacio by way of a Deed of Sale, that they had been in peaceful, public, quiet, and continuous possession in the concept of an owner without any adverse claim from any third person, and that the adjoining owners were duly notified of the survey conducted on the subject property.

The Republic, through the Office of the Solicitor General, filed an Opposition contending that spouses Manzana had not been in open, continuous, exclusive, and notorious possession since June 12, 1945 or prior thereto; that the muniments of title and tax declarations did not constitute competent and sufficient evidence of a bona fide acquisition; that any claim based on Spanish title or grant could no longer be availed of for failure to file within the period prescribed by P.D. No. 892; and that the parcel of land was part of the public domain and not subject to private appropriation.

The Land Registration Authority submitted a Report dated March 18, 2003 noting a discrepancy: when the plan for Lot 5653 was plotted on the Municipal Index Sheet through its tie line, it was found to be in a doubtful position with respect to the plotting of previously applied plans for Lots 5651 and 5650. The LRA referred the matter to the DENR for verification and correction. Spouses Manzana presented three witnesses. Sonia Manzana testified to prove the material allegations of the Application. Jeriel Villanueva, son of Caridad Bonifacio, testified that his mother was in peaceful possession of the property before selling it to spouses Manzana in April 1990, and that even at age seven he was aware that a tenant, Cesario San Agustin, used to bring them harvest from the land. Engr. Ricardo Nilo of the LRA testified on the examination of the documents attached to the Application and the doubtful position of the subject lot.

Engr. Nilo explained that the doubtful position pertained only to the adjoining lands — the technical description, when plotted, fell somewhere not in the correct phase — and that the LRA's findings were not yet final, as it was still requesting a cadastral map from the DENR. He did not recommend approval of the application at that stage. The DENR issued a Reply dated May 26, 2003 stating that the subject lot was "not in doubtful position" with respect to Lots 5651 and 5650, and furnished the LRA with a reproduction copy of the cadastral map and certified lot data computations. However, neither the cadastral map nor the certified lot data computations were submitted to the MTC. On May 10, 2006, Engr. Nilo testified again that, based on the DENR Letter-Reply, the doubtful position remarks were already corrected and the property could be registered in the name of spouses Manzana. A CENRO Report from Antipolo City certified that the subject land fell within the alienable and disposable zone under Land Classification Map No. 639 per Project No. 16, certified released on March 11, 1927.

On May 21, 2008, the MTC received a Letter from the LRA requesting that the trial court direct the applicants to submit copies of the plan and technical description to the DENR for "verification of status of the subject lots." The MTC, through the Clerk of Court, directed spouses Manzana to submit the requested documents on May 22, 2008. The MTC rendered its Decision on June 25, 2008 — before the requested documents were submitted — granting the application and declaring and confirming ownership of Lot 5653 in favor of spouses Manzana. The OSG appealed to the Court of Appeals, which reversed the MTC ruling on the ground that possession since June 12, 1945 was not proven, that Section 14(2) could not apply because the land was not patrimonial, and that doubt remained in the technical description because the LRA had still requested documents to verify the status of the lot even after Engr. Nilo's testimony that the property was no longer in a doubtful position.

• Compliance with Section 14(1) of P.D. No. 1529: Petitioners argued that their predecessor-in-interest had been in open, continuous, exclusive, and notorious possession of the subject property since June 12, 1945 or earlier, citing Tax Declaration No. 3358 registered on December 20, 1948, which bore a notation that it cancelled Tax No. 23772, indicating that the property was already declared in the name of the predecessor-in-interest prior to 1948.
• Alternative entitlement under Section 14(2): Petitioners maintained that even if they did not prove possession since June 12, 1945, they were still entitled to registration because they and their predecessor-in-interest were in open, continuous, exclusive, and notorious possession and occupation in accordance with Section 14(2) of P.D. No. 1529.
• No doubt in technical description: Petitioners averred that there was no doubt in the technical description of the subject lot that would warrant denial of the application.
• Erroneous mode of appeal: Petitioners claimed that the OSG's direct filing of the appeal to the CA was erroneous and that the appeal should have been filed before the Regional Trial Court.

• Improper recourse raising questions of fact: Respondent submitted that petitioners raised purely questions of fact in the petition, which is not proper in a petition for review on certiorari before the Supreme Court under Rule 45.
• Failure to prove compliance with legal requirements: Respondent argued that the CA correctly ruled that petitioners failed to prove full compliance with the requirements under the law necessary for the grant of the application for registration.

• Propriety of Appeal: Whether the OSG properly appealed the MTC Decision directly to the Court of Appeals.
• Retroactive Application of R.A. No. 11573: Whether R.A. No. 11573, which shortened the required period of possession for judicial confirmation of title, applies retroactively to the pending application.
• Sufficiency of Evidence and Need for Remand: Whether the case should be remanded to the court of origin for reception of additional evidence on the 20-year possession requirement and land classification status under R.A. No. 11573.

• Propriety of Appeal: Yes. The OSG correctly appealed the MTC Decision directly to the CA, because MTC decisions in land registration cases are appealable in the same manner as RTC decisions under Section 34 of the Judiciary Reorganization Act of 1980, as amended by R.A. No. 7691.
• Retroactive Application of R.A. No. 11573: Yes. R.A. No. 11573 applies retroactively to all applications for judicial confirmation of title pending as of September 1, 2021, including those before MTCs with delegated jurisdiction and those pending before the Supreme Court, pursuant to Republic vs. Pasig Rizal Co., Inc.
• Sufficiency of Evidence and Need for Remand: The case was remanded. No categorical finding was made on whether the 20-year possession requirement was satisfied, and the CENRO Report originally submitted was insufficient to establish land classification status under the new standards of R.A. No. 11573.

• Propriety of Appeal: The MTC rendered its Decision in the exercise of delegated jurisdiction in cadastral and land registration cases. Section 34 of the Judiciary Reorganization Act of 1980 (B.P. Blg. 129), as amended by R.A. No. 7691, expressly provides that decisions of MTCs in such cases "shall be appealable in the same manner as decisions of the Regional Trial Courts." Since RTC decisions are appealable directly to the CA, the OSG's direct appeal to the CA was proper. On the question of factual review, while Rule 45 generally limits the Court to questions of law, an exception exists when the findings of the appellate court are contrary to those of the trial court — a situation present here, as the CA's findings were contrary to the MTC's.

• Retroactive Application of R.A. No. 11573: While the case was pending, R.A. No. 11573 was enacted and took effect on September 1, 2021. Section 6 amended Section 14(1) of P.D. No. 1529 by shortening the period of possession from "June 12, 1945 or earlier" to "at least twenty (20) years immediately preceding the filing of the application for confirmation of title." Section 7 prescribed that a duly signed certification by a DENR geodetic engineer is sufficient proof of alienable and disposable status. In Republic vs. Pasig Rizal Co., Inc., the Court En Banc declared R.A. No. 11573 to be curative in nature and retroactive in effect, covering applications pending as of September 1, 2021. The Court clarified that the guidelines in Pasig Rizal — though seemingly limited to RTCs and the CA — also apply to cases pending before MTCs, MeTCs, and MCTCs exercising delegated jurisdiction, and to cases pending before the Supreme Court itself. The CA's ground for reversal — failure to prove possession since June 12, 1945 — was therefore no longer controlling.

• Sufficiency of Evidence and Need for Remand: Although the new 20-year standard governed, it was unclear whether twenty years had accrued in favor of spouses Manzana, as no categorical finding on that fact had been made by the trial court. Moreover, the CENRO Report originally submitted was insufficient to determine land classification status under the new standards of Section 7 of R.A. No. 11573, and the MTC had rendered its Decision without waiting for the documents requested by the LRA to be submitted to the DENR for verification of the status of the subject lots. In light of the curative nature of R.A. No. 11573 and the principle of judicial economy, the Court found it appropriate to remand the case to the court of origin for reception of additional evidence to determine, among other things, whether the 20-year requirement was complied with and whether petitioners were entitled to the land based on land classification status and technical description.

• Retroactive Application of Curative Land Registration Laws — A curative statute amending land registration requirements, such as R.A. No. 11573, applies retroactively to all applications for judicial confirmation of title pending as of the date the law took effect. The Court in Republic vs. Pasig Rizal Co., Inc. established that R.A. No. 11573 is curative in nature because its declared purpose is to simplify, update, and harmonize land law provisions, and by shortening the period of adverse possession, it effectively created a new right in favor of those who have possessed alienable and disposable land for the shortened period. The Court in this case extended the application of the Pasig Rizal guidelines to cases pending before MTCs, MeTCs, and MCTCs with delegated jurisdiction, and to cases pending before the Supreme Court.

• Appealability of MTC Decisions in Land Registration Cases — Decisions of MTCs, MeTCs, and MCTCs rendered in the exercise of delegated jurisdiction in cadastral and land registration cases are appealable in the same manner as decisions of Regional Trial Courts, pursuant to Section 34 of B.P. Blg. 129 as amended by R.A. No. 7691, meaning appeals are taken directly to the Court of Appeals.

• Exceptions to the Rule Against Factual Review in Rule 45 Petitions — While the Supreme Court in a Rule 45 petition is not a trier of facts, it may review factual findings when the findings of the appellate court are contrary to those of the trial court, among other recognized exceptions.

• "The guidelines seem to limit its application to the RTC and the CA. However, taking into consideration the curative nature of R.A. No. 11573, the Court takes this opportunity to clarify that cases pending before the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts who have delegated jurisdiction to handle cadastral and land registration cases as provided in R.A. No. 7691 amending Section 34 of BP Blg. 129 and those pending before this Court are also included in these guidelines." — This passage extends the retroactive application of R.A. No. 11573 and the Pasig Rizal guidelines to cases before first-level courts with delegated jurisdiction and to cases pending before the Supreme Court, resolving an ambiguity in the original guidelines.

• "the rule that an applicant for an original registration of title must possess the property since June 12, 1945 or earlier, which was the basis for the CA's denial, is already of no moment. What is now controlling is that the applicant must possess the property in accordance with the new Section 14(1) of P.D. No. 1529 for at least 20 years immediately preceding the filing of the application for confirmation." — This passage articulates the direct effect of R.A. No. 11573's retroactive application on the disposition: the old possession standard relied upon by the CA is superseded.

• "the Court finds it appropriate to remand this case to the court of origin for reception of additional evidence that would determine among others, whether or not the 20-year requirement has been complied with, and whether or not spouses Manzana are entitled to the land based on the land classification status, and technical description." — This passage states the ratio for the remand: factual gaps on the new 20-year requirement and land classification status necessitate further proceedings.

• Republic vs. Pasig Rizal Co., Inc., G.R. No. 213207, February 15, 2022 — Controlling precedent. The Court En Banc declared R.A. No. 11573 retroactive and curative in nature, and laid down the guidelines for its application to pending land registration cases. This case directly governed the Supreme Court's application of the new 20-year possession standard and the directive for reception of additional evidence on land classification.
• Republic vs. Herederos de Ciriaco Chunaco Disteleria Incorporada, 888 Phil. 64 (2020) — Cited for the settled rule on the two requisites for registration under Section 14(1) of P.D. No. 1529: that the land forms part of alienable and disposable land, and that the applicant has been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership from June 12, 1945 or earlier (now superseded by R.A. No. 11573).
• Locsin vs. Hizon, 743 Phil. 420 (2014) — Cited for the rule that the Supreme Court is not a trier of facts in Rule 45 petitions.
• Angeles vs. Pascual, 673 Phil. 499 (2011) — Cited for the recognized exception allowing factual review when the appellate court's findings are contrary to those of the trial court.
• Dr. Malixi vs. Dr. Baltazar, 821 Phil. 423 (2017) — Cited for the principle of judicial economy, supporting the remand to the court of origin.

• Section 14(1), P.D. No. 1529 (Property Registration Decree) — Original provision requiring open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier for judicial confirmation of title. The CA relied on this provision to deny the application; the Supreme Court held it was superseded by R.A. No. 11573.
• Section 14(2), P.D. No. 1529 — Allows registration by those who have acquired ownership of private lands by prescription under existing laws. The CA held this could not apply because the land remained part of the public domain and was not patrimonial.
• Section 6, R.A. No. 11573 — Amended Section 14(1) of P.D. No. 1529 to require possession for at least twenty (20) years immediately preceding the filing of the application for confirmation of title, instead of since June 12, 1945 or earlier. Applied retroactively to the pending case.
• Section 7, R.A. No. 11573 — Prescribed that a duly signed certification by a DENR geodetic engineer, imprinted on the approved survey plan, is sufficient proof that the land is alienable and disposable, with specific contents required. The Court found the CENRO Report originally submitted insufficient under this new standard and directed reception of additional evidence.
• Section 34, B.P. Blg. 129 (Judiciary Reorganization Act of 1980), as amended by R.A. No. 7691 — Provides that MTC decisions in cadastral and land registration cases shall be appealable in the same manner as RTC decisions. Applied to uphold the propriety of the OSG's direct appeal to the CA.
• Rule 45, Section 1, Rules of Court — Provides that petitions for review on certiorari shall raise only questions of law. The Court recognized an exception because the CA's findings were contrary to those of the trial court.

Lazaro-Javier (Acting Chairperson), M. Lopez, and J. Lopez, JJ., concurred. Leonen, SAJ (Chairperson), was on official business.