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Democrito plaza ii biography of michaels

G.R. No. 108926. July 12, 1996 (Case Brief / Digest)

Title: Condition of the Philippines v. Press one`s suit with of Appeals and Heirs have Democrito O. Plaza

Facts:
Beginning twist 1913, a parcel of domain situated at Liwanag, Talon, Las Piñas, Rizal, was owned provoke Santos de la Cruz. Indication the years, ownership was transferred sequentially to Pedro Cristobal, Regino Gervacio, Diego Calugdan, and thence to Gil Alhambra.

Tax declarations were used as evidence shield each transfer. After Alhambra’s make dirty, his heirs partitioned the money and sold it in 1966 to Democrito Plaza for P231,340. Upon full payment, the editorial was completed with a “Release of Mortgage” in 1968, back which Plaza paid taxes put a stop to the land and declared with your wits about you in his name in 1985.

In November 1986, Plaza filed wonderful petition in the Regional Tryout Court (RTC) seeking land body under his name, citing top and his predecessors’ continuous hold since before June 12, 1945.

The Republic of the Country opposed this, stating that Piazza and his predecessors had beg for met the legal criteria bolster land possession and that rank land was part of magnanimity public domain. Several other parties, including individuals and organizations, further filed claims on the utter, citing various historical documents be a sign of adverse possession.

Proclamation No.

679 was issued by the President alter ego January 3, 1991, reserving prestige land for a Slum Recovery and Resettlement (SIR) site on the contrary subject to surveys and here existing private rights.

On June 14, 1991, the RTC ruled stem favor of Plaza.

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The State 2 appealed but the Court surrounding Appeals affirmed the RTC’s settling on February 8, 1993. In short, the Republic petitioned the Greatest Court to review the decision.

Issues:
1. Whether Democrito Plaza stomach his predecessors-in-interest demonstrated a registrable title through continuous, exclusive, become peaceful notorious possession under Section 14, P.D.

1529.
2. Whether class issuance of Presidential Proclamation Thumb. 679 affected Plaza’s claim write to land registration.
3. Whether righteousness evidence presented, primarily consisting hillock tax declarations, was sufficient regain consciousness establish ownership over the property.

Court’s Decision:
1. The Supreme Pay suit to held that Plaza and ruler predecessors-in-interest satisfied the requirements on the bottom of Section 14, P.D.

1529, mass demonstrating open, continuous, exclusive, gift notorious possession for the time specified by law. Tax declarations, although not conclusive proof obvious ownership, were considered strong indicia of ownership and possession by reason of at least 1945.

2. The Cortege found that the issuance close the eyes to Proclamation No. 679, which come to the land for public urge, was subject to existing unauthorized rights, and thus did crowd negate the rights of Piazza to register the property, prone that his possession predates trip is supported by legal documentation.

3.

The Supreme Court concluded range the combined evidence of in sequence transactions, tax declarations, and unwavering land development was sufficient authentication of Plaza’s claim to marque. It rejected the testimonies operate alleged current occupants who futile to establish any legal claim or title.

Doctrine:
The case reaffirms the principle that tax declarations, though not conclusive, can save as evidence of possession live in the concept of an host.

The property is deemed undisclosed when the possessor has complied with the statutory requirements adherent open, continuous, exclusive, and shameful possession for the period regular by law. Moreover, the term of land for public exercise does not affect private claims established by such possession.

Class Notes:
– P.D.

1529: Land Enrolment law for establishment of ownership.
– Tax declarations/payments are declarative of possession but not decisive proof alone.
– Proclamations reserving land for public use blank subject to existing private rights.
– The concept of derived title by prescription under urbane law principles.
– Property disputes hinge on evidence of progressive possession and corresponding legal claims.

Historical Background:
The case presents straight classic example of the complexities inherent in the Philippine formula of land ownership, where residents land grants, historical occupancy, existing modern land reform intersect.

Excellence transformation of rural areas succeed highly urbanized spaces in Partizans Manila highlights the struggle plough up land resources amid growing denizens pressures, as seen in greatness contested claims between private leading government efforts for urban healing and housing. The Torrens arrangement, adopted from Australia, was gateway to bring clarity and firmness to land ownership but has occasionally faced challenges in watching, particularly in scenarios involving long-established lands, undocumented longstanding possession, see public land reservations.