CLT Realty Development Corp. v. Hi-Grade Feeds Corp. G.R. No. 160684, September 2, 2015
Topic: Mandatory Judicial Notice
Doctrine:
The Senate Senate Report Report,, an offici official al act of the legisl legislati atie e !epart !epartment ment,, ma" be ta#en ta#en $%!icial notice of.
Facts:
The properties in dispute were formerly part of the notorious Maysilo Estate left by Gonzalo Tuason, the vastness of which measures 1,66!"6 hectares, stretchin# across $aloocan $ity, %alenzuela, and Malabon, covered by five &'( mother titles or )ri#inal $ertificate of Title &)$T(! )ne of the mother titles is )$T No! **+, the mother title in dispute! dispute! ater on, smaller smaller lots formin# formin# part of the Maysilo Maysilo Estate were sold to different different persons! -everal subse.uent subdivisions, consolidations, and one e/propriation of the Estate Estate,, spawne spawned d numero numerous us le#al le#al disput disputes, es, livin# livin#0up 0up to the name name &'an &'an! ! of (ae (aeat at )mptor.& )mptor.& )ne )ne of these disputed lots was ot "6, the property subect of this liti#ation! The conflict arose due to an overlappin# of the properties of $T and 2i0Grade, which prompted $T $T to file a case for 3nnulment of Transfer $ertificates of Title, 4ecovery of 5osses 5ossessio sion, n, and ama#es ama#es before before the 4e#ion 4e#ional al Trial Trial $ourt $ourt &4T$( &4T$( of $alooc $aloocan an $ity $ity, 7ranch 1"1, doc8eted as $ivil $ase No! $01'+69 a#ainst 2i0Grade!
The Ruling of the RTC:
3fter trial, the 4T$ ruled in favor of $T! 3ccordin# to the 4T$, 2i0Grade:s title, the older title, cannot prevail over $T:s title because it suffers from patent defects and infir infirmit mities ies!! 3lthou# 3lthou#h h 2i0Gra 2i0Grade de paid paid realty realty ta/es ta/es on the subec subectt propert properties ies,, it is not considered as a conclusive proof of ownership! 2i0Grade filed a Motion for New Trial and;or 4econsideration on the #rounds of newly discovered evidence and serious and patent errors in the court:s appreciation of evidence and factual findin#s based on the decision of the court in $ivil $ase No! $0 1'+*1, entitled <('T <('T . Sto. Ni*o +apitbaha"an ssociation.< ssociation.< The 4T$ denied the motion for utter lac8 of merit! 3ccordin# to the 4T$, the rulin# in favor of 2i0Grade in Sto. Ni*o is Ni*o is not a newly0discovered evidence, as 2i0Grade could not have failed to produce such evidence if it e/ercised reasonable dili#ence! 2i0Grade:s reli relianc ancee in the the afor afores esai aid d case case is alre alread ady y moot moot and acade academi micc as the the cour courtt in Sto. Ni*o already Ni*o already reconsidered its decision and upheld the validity of $T:s title!
The Ruling of the Court of ppeals:
urin# the pendency of the appeal, 2i0Grade filed a -otion to !mit an! Ta#e %!icial Notice of (ommittee Report on Senate /n%ir" into Maysilo Estate -ubmitted by the $ommittees on Justice and 2uman 4i#hts and on =rban 5lannin#, 2ousin# and 4esettlement &-enate 4eport( on 1 July 1**>! The $ourt of 3ppeals #ranted the motion in a 4esolution! ?ncluded in the 4esolution, however, is a statement that althou#h the $ourt of 3ppeals ta8es udicial notice of the -enate 4eport, the $ourt of 3ppeals is not bo%n! by the findin#s and conclusions therein! epartin# from the trial court:s findin#s of fact, the $ourt of 3ppeals ruled as baseless the trial court:s reliance on the testimonies of $T:s witnesses, %as.uez and 7ustalino, on the alle#ed patent infirmities and defects in T$T No! +"11! 3ccordin# to the $ourt of 3ppeals, %as.uez and 7ustalino never testified that the issuance of T$T No! +"11 failed to conform to the re#istration procedures in 1*1@, the year it was issued! 3lso, %as.uez and 7ustalino are incompetent to testify on the customary practices in land re#istration at that time! 4eversin# the ecision of the 4T$, the ecision of the $ourt of 3ppeals readsA
!ssue"s#:
Bhether the $ourt of 3ppeals too8 udicial notice of the -enate 4eport!
committed
a
reversible
error
when
it
Ruling:
Ta8in# udicial notice of acts of the -enate is well within the ambit of the law! -ection 1 of 4ule 1"* of the 4evised 4ules on Evidence providesA -E$T?)N 1! Judicial notice, when mandatory! C 3 court shall ta8e udicial notice, without the introduction of evidence, of the e/istence and territorial e/tent of states, their political history, forms of #overnment and symbols o f nationality, the law of nations, the admiralty and maritime courts of the world and their seals, the political constitution and history of the 5hilippines, the official acts of legislative , e/ecutive and udicial departments of the 5hilippines, the laws of nature, the measure of time, and the #eo#raphical divisions! &1a( &Emphasis and underscorin# supplied(
$udicial notice is the co#nizance of certain facts that ud#es may properly ta8e and act on without proof because these facts are already 8nown to themD it is the duty of the court to assume somethin# as a matter of fact without need of further evidentiary support! )therwise stated, by the ta8in# of udicial notice, the court dispenses with the traditional form of presentation of evidence, i.e. the ri#orous rules of evidence and court proceedin#s such as cross0e/amination! The Senate Report, an official act of the legislative department, may be taken judicial notice of.
-ince this $ourt is not a trier of factsF, we are not prepared to adopt the findin#s made by the )J and the -enate, or even consider whether these are admissible as evidence, thou#h such .uestions may be considered by the $ourt of 3ppeals upon the initiative of the parties! ! ! ! The reports cannot conclusively supersede or overturn %udicial decisions& 'ut if admissi'le they may 'e ta(en into account as evidence on the same level as the other pieces of evidence su'mitted 'y the parties. The fact that they )ere rendered 'y the D*$ and the +enate should not& in itself& persuade the courts to accept them )ithout in,uiry. The facts and arguments presented in the reports must still undergo %udicial scrutiny and analysis& and certainly the courts )ill have the discretion to accept or re%ect them. c23
Thus, the -enate 4eport shall not be conclusive upon the courts, but will be e/amined and evaluated based on its probative value! The $ourt of 3ppeals e/plained .uite pointedly why the ta8in# of udicial notice of the -enate 4eport does not violate the republican principle! ThusA 2owever, the .uestion of the bindin# effect of that 4eport upon this $ourt is alto#ether a different matter! $ertainly, a determination by any branch of #overnment on a usticiable matter which is properly before this $ourt for adudication does not bind the latter! The findin# of the -enate committees may be the appropriate basis for remedial le#islation 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 ma8e such a determination and once final, the same binds not only the parties but all a#encies of #overnment!
That there is such a document as the -enate 4eport was all that was conceded by the $ourt of 3ppeals! ?t did not allow the -enate 4eport to determine the decision on the case!
HRF*R, the petition is hereby D!+/!++D ! The ecision and 4esolution of the $ourt of 3ppeals in $30G!4! $% No! '9@@, entitled &('T Realt" eelopment (orporation . i3Gra!e ee!s (orporation, Register of ee!s of -etro -anila, istrict ///,& dated 1> June "9 and "> )ctober "9, respectively, are hereby FF!R/D! +* *RDRD.
