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REPUBLIC v. CARLOS R. VEGA

This case has been cited 6 times or more.

	GR No. 203560 2014-11-10	REPUBLIC v. APOSTOLITA SAN MATEO VELASCO JR., J.
It is true, as cited by the respondent, that in Republic v. Vega,[21] the Court granted a petition for registration even without the requisite DENR approval of the CENRO certification. There, as in this case, the registrant merely presented a CENRO certification that the land is alienable and disposable based on the evidence on record. The Court instead applied the rule on substantial compliance, and said: Indeed, the best proofs in registration proceedings that a land is alienable and disposable are a certification from the CENRO or Provincial Environment and Natural Resources Office (PENRO) and a certified true copy of the DENR's original classification of the land. The Court, however, has nonetheless recognized and affirmed applications for land registration on other substantial and convincing evidence duly presented without any opposition from the LRA or the DENR on the ground of substantial compliance.
	GR No. 192717 2014-03-12	MINDA S. GAERLAN v. REPUBLIC VILLARAMA, JR., J.
Prefatorily, we address the issue raised by respondent that only questions of law may be raised in a petition for review on certiorari. Indeed, the principle is well established that this Court is not a trier of facts. Therefore, in an appeal by certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, only questions of law may be raised.[28] The distinction between a "question of law" and a "question of fact" is settled. There is a question of law when the doubt or difference arises as to what the law is on a certain state of facts, and the question does not call for an examination of the probative value of the evidence presented by the parties-litigants. On the other hand, there is a "question of fact" when the doubt or controversy arises as to the truth or falsity of the alleged facts. Simply put, when there is no dispute as to the facts, the question of whether the conclusion drawn therefrom is correct or not, is a question of law.[29] In Republic v. Vega,[30] the Court held that when petitioner asks for a review of the decision made by a lower court based on the evidence presented, without delving into their probative value but simply on their sufficiency to support the legal conclusions made, then a question of law is raised.
	GR No. 179181 2013-11-18	ROMAN CATHOLIC ARCHBISHOP OF MANILA v. CRESENCIA STA. TERESA RAMOS BRION, J.
The settled rule is that the jurisdiction of this Court over petitions for review on certiorari is limited to the review of questions of law and not of fact. "A question of law exists when the doubt or controversy concerns the correct application of law or jurisprudence to a certain set of facts; or when the issue does not call for an examination of the probative value of the evidence presented, the truth or falsehood of the facts being admitted. A question of fact exists when a doubt or difference arises as to the truth or falsehood of facts or when the query invites calibration of the whole evidence x x x as well as their relation to each other and to the whole, and the probability of the situation."[24]
	GR No. 195097 2012-08-13	REPUBLIC v. MARLON MEDIDA REYES, J.
Judging by the arguments that are raised by the OSG in its petition, the issue delves on the alleged insufficiency of the documents presented by the respondent to support the CA's conclusion that the subject parcels of land have been validly declared alienable and disposable. In Republic v. Vega,[17] we explained that when a petitioner seeks the review of a lower court's ruling based on the evidence presented, without delving into their probative value but only on their sufficiency to support the legal conclusions made, then a question of law is raised. We explained: [T]he Petition raises a question of law, and not a question of fact. Petitioner Republic simply takes issue against the conclusions made by the trial and the appellate courts regarding the nature and character of the subject parcel of land, based on the evidence presented. When petitioner asks for a review of the decisions made by a lower court based on the evidence presented, without delving into their probative value but simply on their sufficiency to support the legal conclusions made, then a question of law is raised.
	GR No. 162322 2012-03-14	REPUBLIC v. BANTIGUE POINT DEVELOPMENT CORPORATION SERENO, J.
Thus, the present rule is that an application for original registration must be accompanied by (1) a CENRO or PENRO[48] Certification; and (2) a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records.[49]
	GR No. 141019 2011-11-23	JOSE TEOFILO MERCADO v. VALLEY MOUNTAIN MINES EXPLORATION VILLARAMA, JR., J.
Thus, as it now stands, aside from a CENRO certification, an application for original registration of title over a parcel of land must be accompanied by a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records in order to establish that the land indeed is alienable and disposable.[100]