Constitutional law•Constitutional Law•Law School Notes•Political Law

Republic of the Philippines vs Asuncion

January 30, 2023 by Vala No Comments

G.R. No. 200772, February 17, 2021.

FACTS:

In 1976, Paciencia Asuncion (Paciencia) and her children filed an application for original registration of title over nine parcels of land located in Bambang, Bulakan, Bulacan. They claimed the simple ownership of the aforementioned lands by inheritance, accretion, and open, continuous, exclusive, and notorious possession under color of title for at least 30 years.

The application was opposed by petitioner Republic of the Philippines, on the ground that the lands covered by the application were unclassified forest lands within the public domain; and that certain parts of the lands covered by the application belong to Molina-Enriquez group and their predecessors-in-interest.

Due to several postponements and repeated motions to reset filed by the parties’ counsels, the case did not progress until April 29, 1986, when Paciencia and her children moved to amend their application to include another lot. In 1989, Paciencia died; and was substituted by her children. The Asuncions entered into a compromise agreement with the Molina-Enriquez group whereby the former withdrew certain parcels of land from their application in exchange for the withdrawal of the latter’s opposition thereto.

In view of the amendment to the application, during the initial hearing, Asuncion presented three witnesses. The Asuncions were able to prove that the lands were alienable and disposable at

the time of the filing of their application, based on the following pieces of evidence: Indorsement from the Bureau of Forest Development and the Bureau of Customs to the effect that the subject lots were no longer needed for public use and would not obstruct navigation, hence alienable and disposable; the survey plans for the claimed parcels, which were duly approved by the Director of Lands; and a decision of the Court of First Instance of Bulacan dated June 23, 1956, which awarded the lots to the spouses Asuncion on the ground of accretion and open and continuous possession since 1933.

In 2001, the trial court admitted the Asuncions’ formal offer of evidence. On the date of the Republic’s presentation of evidence on June 29, 2001, its sole witness from the Regional Office III of the Department of Environment and Natural Resources failed to appear despite the issuance of a subpoena. Due to the absence of a witness, the trial court closed its presentation of evidence and submitted the case for decision.

The trial court rendered the decision in favor of Asuncions; thereby ordering the registration of the lands in question. The Republic filed a motion for reconsideration which was denied. The CA affirmed the ruling.

ISSUE/S:

Whether the Republic was denied due process when: 1) it is deprived of its right to present

evidence.

HELD:

NO. On a number of occasions, the Court had bent backwards more than enough in allowing the Republic ample opportunity to adduce evidence in its behalf controverting that of the applicants. Notwithstanding the lapse of more than two decades since the institution of the petition at bar way back in 1976, and the vast resources available at its command for purposes of collating and crystallizing its evident in support of its Opposition thereto, the Republic as of July, 2001 was still in the process of “fishing” evidence.

In Rep. of the Phils. v. Sps. Gimenez, formal offer of evidence and objections to evidence are a manifestation of the right to due process. However, given the peculiar circumstances of this case, with special attention to the fact that it has been pending for almost 43 years, the Court finds that the Republic was not denied due process. The records reveal that despite the ample time given by the trial court, the Republic was still unable to timely object to the Asuncions’ evidence, as it filed its comment on the latter’s formal offer only on August 6, 2001, more than a month after the final June 30, 2001 deadline set by the trial court, which was on top of the other extensions requested by the Republic after the trial court first acted on the Asuncions’ formal offer in its March 20, 2001 order.

The Republic failed to submit any evidence whatsoever to support its allegation that the disputed parcels are unclassified forest lands of the public domain. On the contrary, the Asuncions submitted testimonies, photographs, and maps to prove that the disputed lands were formed through accretion.

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Republic of the Philippines vs Asuncion

FACTS:

ISSUE/S:

HELD:

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