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REPUBLIC v. CAYETANO L. SERRANO

This case has been cited 4 times or more.

	GR No. 200773 2015-07-08	REPUBLIC v. ANGELINE L. DAYAOEN DEL CASTILLO, J.
The foregoing discourse is in congruity with the principle enunciated in Republic v. Serrano[15] wherein the Supreme Court explicitly pronounced, viz:"While Cayetano failed to submit any certification which would formally attest to the alienable and disposable character of the land applied for, the Certification by DENR Regional Technical Director Celso V. Loriega, Jr., as annotated on the subdivision plan submitted in evidence by Paulita, constitutes substantial compliance with the legal requirement. It clearly indicates that Lot 249 had been verified as belonging to the alienable and disposable area as early as July 18, 1925.
	GR No. 185092 2014-06-04	REPUBLIC v. CORAZON C. SESE MENDOZA, J.
Respondents cite the case of Republic v. Serrano,[7] where the Court stated that a DENR Regional Technical Director's certification, which was annotated on the subdivision plan submitted in evidence, constituted substantial compliance with the legal requirement. The DENR certification enjoyed the presumption of regularity absent any evidence to the contrary.
	GR No. 171136 2013-10-23	REPUBLIC v. LYDIA CAPCO DE TENSUAN LEONARDO-DE CASTRO, J.
While we may have been lenient in some cases[35] and accepted substantial compliance with the evidentiary requirements set forth in T.A.N. Properties, we cannot do the same for Tensuan in the case at bar. We cannot afford to be lenient in cases where the Land Registration Authority (LRA) or the DENR oppose the application for registration on the ground that the land subject thereof is inalienable. In the present case, the DENR recognized the right of the LLDA to oppose Tensuan's Application for Registration; and the LLDA, in its Opposition, precisely argued that the subject property is part of the Laguna Lake bed and, therefore, inalienable public land. We do not even have to evaluate the evidence presented by the LLDA given the Regalian Doctrine. Since Tensuan failed to present satisfactory proof that the subject property is alienable and disposable, the burden of evidence did not even shift to the LLDA to prove that the subject property is part of the Laguna Lake bed.
	GR No. 177790 2011-01-17	REPUBLIC v. CARLOS R. VEGA SERENO, J.
Recently, however, in Republic v. Serrano,[23] the Court affirmed the findings of the trial and the appellate courts that the parcel of land subject of registration was alienable and disposable. The Court held that a DENR Regional Technical Director's certification, which is annotated on the subdivision plan submitted in evidence, constitutes substantial compliance with the legal requirement: While Cayetano failed to submit any certification which would formally attest to the alienable and disposable character of the land applied for, the Certification by DENR Regional Technical Director Celso V. Loriega, Jr., as annotated on the subdivision plan submitted in evidence by Paulita, constitutes substantial compliance with the legal requirement. It clearly indicates that Lot 249 had been verified as belonging to the alienable and disposable area as early as July 18, 1925.