B2022 ANNOTATED
De La Cruz v. Court of Appeals
I. CARINGAL RECIT READY SUMMARY
Facts of the case
Petitioner De La Cruz claims to be the owner and actual possessor of the
lot, having possessed and occupied it openly, publicly, and notoriously,
adversely against the whole world, and in the concept of an owner for more
than 30 years. Private respondent Cristina Madlangsakay Villanueva is a
purchaser of the same lot from the Private Respondents the Ramos brothers,
who claim to be successors-in-interest of a previous possessor of the
disputed lot.
In October 1959, the Petitioner contracted a loan from the parents of the
private respondent, mortgaging the disputed land as security. In 1973, the
land became the subject of an application for registration under the Land
Registration Act by the Ramos brothers. They insisted that they had a better
claim to the land than the petitioner being successors-in-interest of a
previous possessor of the land. The Court denied the application on the
grounds that the disputed lands were part of the forest and was inalienable.
Shortly after the denial, the Ramos brothers still pursued the application and
was thus successful in having it reclassified and they were granted with
ownership of the land. The Ramos brothers then sold it to Cristina
Madlangsakay Villanueva (the other private respondent).
When Petitioner De La Cruz came to know of the sale, he filed a complaint
for reconveyance and damages, entitled Eugenio De La Cruz vs. Cristina
Madlangsakay Villanueva but the complaint was dismissed.
On Appeal, petitioner De La Cruz said that it was his uncle who gave this
land to his mother in 1930 after having purchased the land from a certain
Cecilio Espiritu. The appellate court affirmed the RTC/CFI (Not sure if
it was already RTC or still CFI) decision. (CA SAID FUKAWTAHERE
WITH UR COWBOY STORY JK)
G.R. NO: 3824092340972340932740293740239472309472482370473490280374098234298374238473289
ARTICLE;
February 11, 1998
De La Cruz v. Court of Appeals
Issue
WON The CA erred in dismissing the complaint (NO)
Ratio/Legal Basis
Petitoner De La Cruz relied on the ruling in Republic v. Court of Appeals
and Miguel Marcelo, et al. where this court held that the primary right of a
private individual who possessed and cultivated the land in good faith,
much prior to its classification, must be recognized and should not be
prejudiced by after-events which could not have been anticipated. He also
relies on the principle of estoppel, alleging that, by virtue of the mortgage
deal between him and the private respondent’s parents, they tacitly
acknowledged him as the owner of the property.
The Court ruled that the Republic v. CA and Marcelo case is inapplicable.
In that case, the disputed land was classified after the possession and
cultivation in good faith of the applicant. In THIS case, the Petitioner
possessed and occupied the land AFTER it had been declared by the
Government as part of the forest zone. In fact, the land remained part of the
forest reserve until the Ramos brothers actions which reclassified it into
alienable and disposable land.
The Petitioner also cannot rely on prescription as prescription can never lie
against the Government. The lengthy stay of the petitioner cannot be
counted in his favor as the land remained part of the patrimonial property of
the state and thus inalienable(PRE-RAMOS RECLASSIFICATION).
Petitioner’s claim on estoppel must also fail. Petitioner invokes estoppel in
light of the contract of mortgage between him and the parents of the private
respondents. While it is true that mortgagees, having entered into contract
with petitioner as mortgagor, are estopped from questioning the latter’s
ownership of the mortgaged property, It must also be considered that in the
first place the petitioner did not have the capacity to encumber the disputed
lands because it has been classified as a forest and is thus inalienable and is
a patrimonial property of the state.
Disposition
AFFIRMED THE FINDINGS OF THE CA.
Notes
PONENTE: JUSTICE LEAGUE S OF PAR NASAN NA YUNG KASAMA NIYO PAR
DIGEST MAKER: ABBY BINAY SUSPEND PLS
 B2022 ANNOTATED February 11, 1998
De La Cruz v. Court of Appeals De La Cruz v. Court of Appeals

G.R. NO: 3824092340972340932740293740239472309472482370473490280374098234298374238473289 PONENTE: JUSTICE LEAGUE S OF PAR NASAN NA YUNG KASAMA NIYO PAR
ARTICLE; DIGEST MAKER: ABBY BINAY SUSPEND PLS