14 CLT Realty Development Corp v. Hi-Grade Feeds

CLT Realty Development Corp. v. Hi-Grade Feeds Corp.
G.R. No. 160684, September 2, 2015
Topic: Mandatory Judicial Notice
Doctrine:
The Senate Report, an official act of the legislative department, may be taken
judicial notice of.
Facts:
The properties in dispute were formerly part of the notorious Maysilo Estate left by
Gonzalo Tuason, the vastness of which measures 1,660.26 hectares, stretching across
Caloocan City, Valenzuela, and Malabon, covered by five (5) mother titles or Original
Certificate of Title (OCT). One of the mother titles is OCT No. 994, the mother title in
dispute. Later on, smaller lots forming part of the Maysilo Estate were sold to different
persons. Several subsequent subdivisions, consolidations, and one expropriation of the
Estate, spawned numerous legal disputes, living-up to the name "Land of Caveat
Emptor." One of these disputed lots was Lot 26, the property subject of this litigation.
The conflict arose due to an overlapping of the properties of CLT and Hi-Grade, which
prompted CLT to file a case for Annulment of Transfer Certificates of Title, Recovery of
Possession, and Damages before the Regional Trial Court (RTC) of Caloocan City,
Branch 121, docketed as Civil Case No. C-15463 against Hi-Grade.
The Ruling of the RTC:

After trial, the RTC ruled in favor of CLT. According to the RTC, Hi-Grade's title,
the older title, cannot prevail over CLT's title because it suffers from patent defects and
infirmities. Although Hi-Grade paid realty taxes on the subject properties, it is not
considered as a conclusive proof of ownership.
Hi-Grade filed a Motion for New Trial and/or Reconsideration on the grounds of
newly discovered evidence and serious and patent errors in the court's appreciation of
evidence and factual findings based on the decision of the court in Civil Case No. C-
15491, entitled "CLT v. Sto. Niño Kapitbahayan Association."
The RTC denied the motion for utter lack of merit. According to the RTC, the ruling
in favor of Hi-Grade in Sto. Niño is not a newly-discovered evidence, as Hi-Grade could
not have failed to produce such evidence if it exercised reasonable diligence. Hi-Grade's
reliance in the aforesaid case is already moot and academic as the court in Sto.
Niño already reconsidered its decision and upheld the validity of CLT's title.
The Ruling of the Court of Appeals:
During the pendency of the appeal, Hi-Grade filed a Motion to Admit and Take
Judicial Notice of Committee Report on Senate Inquiry into Maysilo Estate Submitted by
the Committees on Justice and Human Rights and on Urban Planning, Housing and
Resettlement (Senate Report) on 1 July 1998. The Court of Appeals granted the motion in
a Resolution. Included in the Resolution, however, is a statement that although the Court
of Appeals takes judicial notice of the Senate Report, the Court of Appeals is not bound
by the findings and conclusions therein. S
Departing from the trial court's findings of fact, the Court of Appeals ruled as
baseless the trial court's reliance on the testimonies of CLT's witnesses, Vasquez and
Bustalino, on the alleged patent infirmities and defects in TCT No. 4211. According to
the Court of Appeals, Vasquez and Bustalino never testified that the issuance of TCT No.
4211 failed to conform to the registration procedures in 1917, the year it was issued.
Also, Vasquez and Bustalino are incompetent to testify on the customary practices in land
registration at that time. Reversing the Decision of the RTC, the Decision of the Court of
Appeals reads:
Issue(s):
Whether the Court of Appeals committed a reversible error when it
took judicial notice of the Senate Report.
Ruling:
Taking judicial notice of acts of the Senate is well within the ambit of the law.
Section 1 of Rule 129 of the Revised Rules on Evidence provides:
SECTION 1. Judicial notice, when mandatory. — A court shall take judicial
notice, without the introduction of evidence, of the existence and territorial extent of
states, their political history, forms of government and symbols of nationality, the law
of nations, the admiralty and maritime courts of the world and their seals, the
political constitution and history of the Philippines, the official acts of legislative,
executive and judicial departments of the Philippines, the laws of nature, the measure
of time, and the geographical divisions. (1a) (Emphasis and underscoring supplied)
Judicial notice is the cognizance of certain facts that judges may properly take and
act on without proof because these facts are already known to them; it is the duty of the
court to assume something as a matter of fact without need of further evidentiary
support. Otherwise stated, by the taking of judicial notice, the court dispenses with the
traditional form of presentation of evidence, i.e. the rigorous rules of evidence and court
proceedings such as cross-examination.
The Senate Report, an official act of the legislative department, may be taken
judicial notice of.
Since this Court is not a trier of fact[s], we are not prepared to adopt the findings
made by the DOJ and the Senate, or even consider whether these are admissible as
evidence, though such questions may be considered by the Court of Appeals upon the
initiative of the parties. . . . The reports cannot conclusively supersede or
overturn judicial decisions, but if admissible they may be taken into account as
evidence on the same level as the other pieces of evidence submitted by the
parties. The fact that they were rendered by the DOJ and the Senate should not,
in itself, persuade the courts to accept them without inquiry. The facts and
arguments presented in the reports must still undergo judicial scrutiny and
analysis, and certainly the courts will have the discretion to accept or reject
them. cHA
Thus, the Senate Report shall not be conclusive upon the courts, but will be
examined and evaluated based on its probative value. The Court of Appeals explained
quite pointedly why the taking of judicial notice of the Senate Report does not violate the
republican principle. Thus:
However, the question of the binding effect of that Report upon this Court is
altogether a different matter. Certainly, a determination by any branch of government
on a justiciable matter which is properly before this Court for adjudication does not
bind the latter. The finding of the Senate committees may be the appropriate basis for
remedial legislation but when the issue of the validity of a Torrens title is submitted
to a court for resolution, only the latter has the competence to make such a
determination and once final, the same binds not only the parties but all agencies of
government.
That there is such a document as the Senate Report was all that was conceded by the
Court of Appeals. It did not allow the Senate Report to determine the decision on the
case.
WHEREFORE, the petition is hereby DISMISSED. The Decision and Resolution of the
Court of Appeals in CA-G.R. CV No. 53770, entitled "CLT Realty Development
Corporation v. Hi-Grade Feeds Corporation, Register of Deeds of Metro Manila,
District III," dated 18 June 2003 and 28 October 2003, respectively, are
hereby AFFIRMED.
SO ORDERED.

14 CLT Realty Development Corp v. Hi-Grade Feeds

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CLT Realty Development Corp. v. Hi-Grade Feeds Corp.

G.R. No. 160684, September 2, 2015

Topic: Mandatory Judicial Notice

The Ruling of the RTC:

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