HEIRS OF SPOUSES CRISPULO FERRER and ENGRACIA PUHAWAN,

represented by ROMEO F. GAZA as Attorney-in-Fact

Versus

Court of Appeals, Napocor, etc.

G.R. NO. 190384

Facts:

Issue:

Held:

The petitioners insist that the Bureau of Lands certificate, stating that their
predecessor Crispulo Ferrer was a survey claimant of the property covered by
Cadastral Survey No. 90 of Lumban, Laguna, sufficiently establishes their claim
over Lot 1873, despite our consistent ruling that the certificate is no proof of
title of ownership over the property.
 
A survey made in a cadastral proceeding merely identifies each lot preparatory
to a judicial proceeding for adjudication of title to any of the lands upon claim
of interested parties. The purpose of a survey plan is simply to identify and
delineate the extent of the land. It is not a proof of ownership of the land
covered by the plan. In the present case, the petitioners were not even able to
present the actual survey plan approved by the Bureau of Lands; all that they
relied on was the Bureau of Lands certificate that proved nothing more beyond
than what was expressly stated therein: that Lot 1873 is in the name of Crispulo
Ferrer, as a survey claimant.