AUTHORITY OF COURT OF APPEALS TO CONFIRM A TITLE OF OPPOSITOR

SUBJECT TO CONDITIONS
ROMAN CATHOLIC ARCHBISHOP OF MANILA VS. CRESENCIA STA. TERESA
RAMOS
G.R. 179181, November 18, 2013
Brion, J:
FACTS:
Roman Catholic Archbishop of Manila (RCAM) filed an application for registration of
title of two (2) parcels of land in the Regional Trial Court of Rizal acting as land
registration court. To support the claim of ownership, RCAM presented technical
description of two (2) lots, a surveyors certificate and tax declarations issued on
1966. On the other hand, Cresencia Sta. Teresa Ramos filed her opposition. She
alleged that the property formed part of the entire property that her family owns
and has continuously possessed and occupied from the time of her grandparents
during Spanish time, up to the present. To further support her claim and her prayer
for confirmation of imperfect title, she presented the death certificates of her
parents, marriage certificate and several photographs of their established business
on the subject lots claiming possession over the property. The Regional Trial Court
denied the petition of RCAM and affirmed the ownership of Cresencia but refused to
issue title in Cresencias name. The Court of Appeals on the other hand, affirmed
the decision of RTC with modification, confirming the incomplete and imperfect title
of Cresencia. RCAM questions the propriety of the CAs confirmation of Cresencias
title over the property since she was not an applicant and merely the oppositor in
the confirmation and registration proceedings RCAM filed.
ISSUE:
Can the Court of Appeals confirm oppositors title over the property on the basis of
the documents presented by Cresencia?
HELD:
NO. While the Supreme Court upholds the authority of the Court of Appeals to
confirm the title of the oppositor in a confirmation and registration proceedings, the
court did not agree with the conclusion reached by the Court of Appeals in
confirming the title of Cresencia. The various pieces of documentary evidence that
Cresencia presented to support her own claim of imperfect title hardly proved her
alleged actual possession of the property.
Like RCAM, Cresencia was bound to
adduce irrefutable evidence that proves her compliance with the requirements for
confirmation of title.
Further, both parties failed to prove the first and most basic requirement to confirm
a title that is the presentation of competent and persuasive evidence in proving that
the property is alienable and disposable.