This case has been cited 2 times or more.
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2011-03-07 |
VILLARAMA, JR., J. |
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| In Limcoma Multi-Purpose Cooperative v. Republic,[20] we have ruled that a certification and report from the DENR-CENRO enjoys the presumption of regularity and is sufficient proof to show the classification of the land described therein. We held: In the recent case of Buenaventura v. Republic,[21] we ruled that said Certification is sufficient to establish the true nature or character of the subject property as public and alienable land. We similarly ruled in Republic v. Court of Appeals[22] and intoned therein that the certification enjoys a presumption of regularity in the absence of contradictory evidence. | |||||
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2007-09-13 |
AZCUNA, J. |
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| Although tax declarations, as a rule, are not conclusive evidence of ownership, they are proof that the holder has a claim of title over the property and serve as sufficient basis for inferring possession. These tax declarations bolster the respondent's claim that her predecessor-in-interest possessed and occupied the lots even before the period prescribed by law.[34] The fact that the earliest tax declarations of the lots were for the year 1955 will not mitigate against respondent. In Recto v. Republic,[35] it was held that:x x x the belated declaration of the lot for tax purposes does not necessarily mean that possession by the previous owners thereof did not commence in 1945 or earlier. As long as the testimony supporting possession for the required period is credible, the court will grant the petition for registration.[36] Petitioner asserts that reliance on the certification issued by the CENRO, officially stating that the properties are alienable, is incorrect inasmuch as the issuing officer did not testify in court; therefore, such evidence "in point of strict law" may be "constitutive of hearsay." | |||||