Civil Law

Pedro Santiago vs Subic Bay Metropolitan Authority

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G. R. No. 156888 – 507 SCRA 283 – Civil Law – Land Titles and Deeds – Spanish Titles Inadmissible as Evidence

In 1994, Victoria Rodriguez inherited a parcel of land from his father. She leased the land to Pedro Santiago and Armando Mateo for a period of 50 years. Subic Bay Metropolitan Authority (SBMA) also claimed ownership of the same parcel of land. SBMA alleged that they only let the Santiagos into the land as part of the employment benefits given to Santiago’s wife, as she was formerly employed by SBMA. But when her employment ended in 1998, SBMA is now ousting them. Rodriguez et al filed a petition against SBMA. Rodriguez presented a Spanish title of land to show proof of her ownership. RTC dismissed the petition for lack of cause of action. The RTC took judicial notice of Presidential Decree No. 892, which required all holders of Spanish titles or grants to apply for registration of their lands under Republic Act No. 496, otherwise known as the Land Registration Act, within six months from effectivity of the decree, or until 16 August 1976. After such time, Spanish titles or grants could no longer be used as evidence of land ownership in any registration proceedings under the Torrens System.

ISSUE: Whether or not Spanish Titles are admissible as evidence of ownership.

HELD: No. Titulo de Propriedad de Terrenos of 1891, cannot be considered a right in esse. Spanish titles can no longer be countenanced as indubitable evidence of land ownership. And, without legal or equitable title to the subject property, Victoria M. Rodriguez, Armando G. Mateo, and Pedro R. Santiago lacked the personality to claim entitlement to possession of the same. Title to real property refers to that upon which ownership is based. It is the evidence of the right of the owner or the extent of his interest, by which means he can maintain control and, as a rule, assert right to exclusive possession and enjoyment of the property. Rodriguez should have registered the land before August 16, 1976.

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