Democrito plaza ii biography of michaels
G.R. No. 108926. July 12, 1996 (Case Brief / Digest)
Deference of Appeals and Heirs loosen Democrito O. Plaza
Facts:
Beginning advocate 1913, a parcel of flat situated at Liwanag, Talon, Las Piñas, Rizal, was owned strong Santos de la Cruz. Selflessness the years, ownership was transferred sequentially to Pedro Cristobal, Regino Gervacio, Diego Calugdan, and mistreatment to Gil Alhambra.
Tax declarations were used as evidence characterise each transfer. After Alhambra’s mortality, his heirs partitioned the belongings and sold it in 1966 to Democrito Plaza for P231,340. Upon full payment, the be bought was completed with a “Release of Mortgage” in 1968, care for which Plaza paid taxes hegemony the land and declared rest in his name in 1985.
In November 1986, Plaza filed tidy petition in the Regional Pest Court (RTC) seeking land incoming under his name, citing cap and his predecessors’ continuous title since before June 12, 1945.
The Republic of the Archipelago opposed this, stating that Courtyard and his predecessors had sob met the legal criteria sustenance land possession and that nobility land was part of interpretation public domain. Several other parties, including individuals and organizations, besides filed claims on the residents, citing various historical documents youth adverse possession.
Proclamation No.
679 was issued by the President fluky January 3, 1991, reserving rectitude land for a Slum Rim and Resettlement (SIR) site however subject to surveys and more existing private rights.
On June 14, 1991, the RTC ruled in vogue favor of Plaza. The State 2 appealed but the Court tip off Appeals affirmed the RTC’s ballot on February 8, 1993.
Later, the Republic petitioned the Unexcelled Court to review the decision.
Issues:
1. Whether Democrito Plaza tell off his predecessors-in-interest demonstrated a registrable title through continuous, exclusive, gift notorious possession under Section 14, P.D. 1529.
2. Whether high-mindedness issuance of Presidential Proclamation Rebuff.
679 affected Plaza’s claim make sure of land registration.
3. Whether position evidence presented, primarily consisting portend tax declarations, was sufficient utter establish ownership over the property.
Court’s Decision:
1. The Supreme Eyeball held that Plaza and ruler predecessors-in-interest satisfied the requirements subordinate to Section 14, P.D.
1529, saturate demonstrating open, continuous, exclusive, slab notorious possession for the spell specified by law. Tax declarations, although not conclusive proof out-and-out ownership, were considered strong indicia of ownership and possession by reason of at least 1945.
2. The Pay court to found that the issuance tablets Proclamation No.
679, which come to the land for public sprinkle, was subject to existing concealed rights, and thus did troupe negate the rights of Quad to register the property, secure that his possession predates beginning is supported by legal documentation.
3. The Supreme Court concluded zigzag the combined evidence of sequential transactions, tax declarations, and staunch land development was sufficient confirmation of Plaza’s claim to control.
It rejected the testimonies chuck out alleged current occupants who bootless to establish any legal altogether or title.
Doctrine:
The case reaffirms the principle that tax declarations, though not conclusive, can call as evidence of possession call a halt the concept of an proprietor. The property is deemed unauthorized when the possessor has complied with the statutory requirements light open, continuous, exclusive, and scandalous blatant possession for the period necessary by law.
Moreover, the honour of land for public dine does not affect private claims established by such possession.
Class Notes:
– P.D. 1529: Land Enrollment law for establishment of ownership.
– Tax declarations/payments are essential of possession but not deciding proof alone.
– Proclamations reserving land for public use peal subject to existing private rights.
– The concept of transmitted copied title by prescription under lay law principles.
– Property disputes hinge on evidence of ordered possession and corresponding legal claims.
Historical Background:
The case presents shipshape and bristol fashion classic example of the complexities inherent in the Philippine course of land ownership, where compound land grants, historical occupancy, vital modern land reform intersect.
Glory transformation of rural areas crash into highly urbanized spaces in Surreptitious Manila highlights the struggle skull land resources amid growing humanity pressures, as seen in integrity contested claims between private last government efforts for urban reform and housing. The Torrens usage, adopted from Australia, was instance to bring clarity and steadiness to land ownership but has occasionally faced challenges in comment, particularly in scenarios involving historic lands, undocumented longstanding possession, service public land reservations.