CASE 2017-0041: TOMAS R. LEONIDAS VS. TANCREDO VARGAS AND REPUBLIC OF THE PHILIPPINES (G.R. NO. 201031, 14 DEC 2017, DEL CASTILLO, J.) (SUBJECT/S: LAND REGISTRATION; TAX DECLARATION ONLY CORROBORATIVE PROOF OF POSSESSION; IRREGULAR LAND TAX PAYMENTS DO NOT PROVE CLAIM OF POSSESSION OR OWNERSHIP) (BRIEF TITLE: LEONIDAS VS. VARGAS ET AL).

 

DISPOSITIVE:

 

“WHEREFORE, the Petition is hereby DENIED. We AFFlRM with MODIFICATION  the August 13, 2009 Decision and the February 22, 2012 Resolution of the Court of Appeals in CA-G.R. CV No. 02296 in that the award by the Regional Trial Court of Barotac Viejo, Hoilo, Branch 66 in LRC Case No. 02~ 195 of Lot No. 1677 with aP.. area of 2.3642 hectares and Lot No. 566 with an area of 1.1 782 hectares, both in ‘favor of Respondent Tancredo Vargas, is OVERTURNED and NULLIFIED.

 

SO ORDERED.”

 

SUBJECTS/DOCTRINES/DIGEST:

 

 HOW IS TAX DECLARATIONS CONSIDERED IN LAND CASES?

 

TAX DECLARATIONS ARE MERELY CORROBORATIVE OF A PERSON’S CLAIM OF POSSESSION.

 

HOW ABOUT IRREGULAR TAX PAYMENTS?

 

THEY DO NOT REALLY PROVIDE STRONG SUPPORT FOR A CLAIM OF OWNERSHIP OR POSSESSION.

 

 It would thus appear that Tancredo had erected his opposition/claim to the lots in question upon the said photocopies of four tax declarations whose authenticity or genuineness is open to the most serious doubts. And, even on the assumption that the said tax declarations are in fact authentic and genuine, still it is settled that tax declarations are not conclusive proof of ownership. If anything, tax declarations are merely corroborative of a person’s claim of possession. More than that, as elsewhere indicated, intermittent and irregular tax payments, as in this case, do not really provide  strong support for a claim of ownership or possession.

 

WHAT IS THE POLICY OF THE STATE IN CONNECTION WITH ALIENABLE PUBLIC LANDS?

 

TO ENCOURAGE AND PROMOTE THE DISTRIBUTION OF ALIENABLE PUBLIC LANDS TO SPUR ECONOMIC GROWTH BUT SAFEGUARDS ARE IMPOSED LEST SUCH LANDS FALL INTO WRONG HANDS TO THE PREJUDICE OF THE NATIONAL PATRIMONY.

 

It is axiomatic of course that “[i]t is the policy of the State to encourage and promote the distribution of alienable public lands as a spur to economic growth and in line with the social justice ideal enshrined in the Constitution. At the same time, the law imposes stringent safeguards upon the grant of such resources lest they fall into the wrong hands to the prejudice of the national patrimony.”63 This ruling controls the present case.

  

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SCD-2017-0041-TOMAS R. LEONIDAS VS. TANCREDO VARGAS AND REPUBLIC OF THE PHILIPPINES

 

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