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    Facts: Private Respondent Jose Lachica Filed An Application For Title To Land in April, 1958 With The

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    sophiabarnachea
    Petitioners opposed an application for land title, arguing the applicant did not prove purchase through a lost deed. The trial court and appellate court ruled for the applicant based on his tax declarations. The Supreme Court reversed, finding tax declarations alone are not conclusive of ownership, and the belated and inconsistent declarations here did not prove the applicant's ownership claim.

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    Facts: Private Respondent Jose Lachica Filed An Application For Title To Land in April, 1958 With The

    Uploaded by

    sophiabarnachea
    18 views1 page
    Petitioners opposed an application for land title, arguing the applicant did not prove purchase through a lost deed. The trial court and appellate court ruled for the applicant based on his tax declarations. The Supreme Court reversed, finding tax declarations alone are not conclusive of ownership, and the belated and inconsistent declarations here did not prove the applicant's ownership claim.

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    39.-ALBA-VDA

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    Petitioners opposed an application for land title, arguing the applicant did not prove purchase through a lost deed. The trial court and appellate court ruled for the applicant based on his tax declarations. The Supreme Court reversed, finding tax declarations alone are not conclusive of ownership, and the belated and inconsistent declarations here did not prove the applicant's ownership claim.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    18 views1 page

    Facts: Private Respondent Jose Lachica Filed An Application For Title To Land in April, 1958 With The

    Uploaded by

    sophiabarnachea
    Petitioners opposed an application for land title, arguing the applicant did not prove purchase through a lost deed. The trial court and appellate court ruled for the applicant based on his tax declarations. The Supreme Court reversed, finding tax declarations alone are not conclusive of ownership, and the belated and inconsistent declarations here did not prove the applicant's ownership claim.

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    ALBA VDA. DE RAZ vs.

    COURT OF APPEALS
    G.R. No. 120066, September 9, 1999

    Facts:   

      Private respondent Jose Lachica filed an application for title to land in April, 1958 with the
    claim that the land applied for was purchased by him and his wife.  Petitioners opposed contending that
    the applicant did not show proof of the alleged sale because the deed of conveyance was allegedly lost
    and therefore was not presented in the proceedings.  However, the TC rendered judgment in favor of the
    applicant noting that said oppositors never offered any explanation as to the non-payment of realty taxes
    for the disputed portions of the land from 1941-1958 while respondent continuously paid taxes thereon.  It
    stressed that while it is true that tax receipts and tax declaration of ownership for tax purposes are not
    incontrovertible evidence of ownership, they become strong evidence of ownership acquired by
    prescription when accompanied by proof of actual possession.  The CA affirmed stating that it is of no
    moment that the applicant failed to produce the original of the deed/conveyances for he was able to
    present sufficient substantial secondary evidence in accordance with the Rules of Court.  Hence this
    appeal.

    Issue:     Is private respondent entitled to the confirmation of his ownership of the subject land?

    Held:     

    Both the TC and CA placed undue reliance on the Tax declarations which by itself is not a
    conclusive evidence of ownership.  Tax declaration for a certain number of years although constituting
    proof of claim of title to land is not incontrovertible evidence of ownership unless they are supported by
    other effective proof.  A belated declaration is, furthermore, indicative that the applicant had no real claim
    of ownership over the subject land prior to the declaration and where there are serious discrepancies in the
    tax declarations, as in this case, registration should be denied.

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