Civil Law,  Legally Yours

Del Castillo Case Doctrines (Civil Law – Land Titles and Deeds)

Del Castillo Case Doctrines

Summaries of case doctrines penned by Justice Del Castillo.

Civil Law Land Titles and Deeds

Andres v. Sta. Lucia Realty & Development, Inc.
G.R. No. 201405, August 24, 2015

Only lands of public domain subsequently classified or declared as no longer intended for public use or removed from the sphere of public dominion are considered controverted into patrimonial lands which may be alienated or disposed of through any of the modes of acquisition.

Coderia v. Estate of Juan Chioco
G.R. No. 180476, June 26, 2013

The Court cannot sanction the use of force to evict beneficiaries of land reform, the same being a reversion to the feudal system, where the landed elite have free rein over the poor vassals. Thus, under equitable considerations, the three-year prescriptive period for filing cases under Section 38 of the Agricultural Land Reform Code may be relaxed.

Mahinay v. Hon. Gako, Jr.
G.R. No. 165338, November 28, 2011

The maxim prior est tempore, potior est jure (he who is first in time is preferred in right) is followed in land registration. When a mortgagee relies upon what appears on the face of a Torrens title and lends money in all good faith based on the title in the name of the mortgagor, his or her right or lien upon the land mortgaged must be respected and protected.

Meyr Enterprises Corporation v. Cordero
G.R. No. 197336, September 3, 2014

A private person has no personality to sue with regard to a public land.

Oliveros v. San Miguel Corporation
G.R. No. 173531, February 1, 2012

The principle that the earlier title prevails over a subsequent one applies only when there are two apparently valid titles over a single property. Without a title, one cannot invoke the principle of indefeasibility of Torrens titles nor can he assert priority or presumptive conclusiveness.

Palali v. Awisan
G.R. No. 158385, February 12, 2010

Tax declarations, by themselves, are not conclusive evidence of ownership of real property. In the absence of actual, public, and adverse possession, the declaration of the land for tax purposes does not prove ownership.

Palomata v. Colmenares
G.R. 174251, December 15, 2010

The presumption of ownership is not applicable if the nature of the possession of the claimant is as tenant-farmers.

Republic of the Philippines v. AFP Retirement and Separation Benefits System
G.R. No. 180463, January 16, 2013

The vested rights of the heirs over a parcel of land cannot prevail against the ownership of the government of public lands under the Regalian Doctrine.

Republic of the Philippines v. Cortez, Sr.
G.R. No. 197472, September 7, 2015

Pursuant to the Regalian Doctrine, all lands of the public domain belong to the state. Thus, possession of lands of the public domain will not ripen into ownership

Republic of the Philippines v. Dayaoen
G.R. No. 200773, July 8, 2015

To prove that the land subject of an application for registration is alienable, an applicant must establish the existence of a positive act of the government such as presidential proclamation or an executive order, an administrative action, investigation reports of the Bureau of Lands investigators, and a legislative act or statue. Mere annotations appearing in survey plans are inadequate proof of the covered properties’ alienable and disposable character.

Republic of the Philippines v. Spouses Benigno
G.R. No. 205492, March 11, 2015

Applicants for registration of title under PD 1529 must prove:
1) that the subject land forms part of the disposable and alienable lands of the public domain; and
2) that they have been in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since 12 June 1945 or earlier.

In order to prove that the land subject of the application is alienable and disposable public land, all applications for original registration under the Property Registration Decree must include both
1) a CENRO or PENRO certification; and
2) a certified true copy of the original classification made by the DENR Secretary.

Spouses Tabino v. Tabino
G.R. No. 196219, July 30, 2014

Under CA 141, the Director of Lands, primarily, and the DENR Secretary, ultimately, have the authority to dispose of and manage public lands. While the DENR’s jurisdiction over public lands does not negate the authority of the courts to resolve questions of possession, the DENR’s decision would prevail with regard to the rights of public land claimants. Thus, regular courts have no jurisdiction to inquire into the validity of the award of the public land.

Spouses Valenzuela v. Spouses Mano
G.R. No. 172611, July 9, 2010

A Torrens title is not a conclusive evidence of ownership when the land or a portion covered thereof was illegally or erroneously included thereto. The certificate of title cannot be used to protect a usurper from the true owner.

Spouses Vilbar v. Opinion
G.R. No. 176043, January 15, 2014

Registration is the operative act which gives validity to the transfer or creates a lien upon the land.

Wee v. Republic of the Philippines
G.R. No. 177384, December 8, 2009

One who seeks the registration of his title must prove his claim with incontrovertible evidence. “Mere casual cultivation” of the land does not amount to exclusive and notorious possession that would give rise to ownership.

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