Reyes v. Republic
REITERATIONFacts
The Antecedents: Petitioner Vernon T. Reyes filed an application for confirmation and registration of imperfect title over a parcel of land in Silang, Cavite, with an area of 43,514 square meters. He alleged that the land was adjudicated in his favor through a Deed of Extra-Judicial Settlement executed on December 24, 1992, by the grandchildren of the late Eusebio Vicente. Procedural History: The Regional Trial Court (RTC) of Tagaytay City approved the application. The Republic of the Philippines appealed to the Court of Appeals (CA), which reversed the RTC's decision, dismissing the application. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, contending that the CA erred in holding that he failed to present incontrovertible evidence of possession for the length of time required by law. The Republic maintained that petitioner failed to satisfy the requisite quantum of evidence.
Issue(s)
Whether petitioner presented sufficient evidence to prove open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945, or earlier. Whether the Court of Appeals erred in reversing the RTC's decision and dismissing the application for registration.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the failure to prove possession since June 12, 1945: The Court reiterated that applicants for confirmation and registration of imperfect title must prove two things: (a) that the land forms part of the alienable lands of the public domain; and (b) that they have been in open, continuous, exclusive, and notorious possession and occupation of the same under a bona fide claim of ownership either since time immemorial or since June 12, 1945. The Court of Appeals found that while the property was alienable and disposable, the petitioner failed to prove the required possession. Petitioner's possession commenced on December 24, 1992, when the land was adjudicated to him, and he filed his application in 1996, meaning he possessed the land for only four years. To bridge the gap, he claimed tacking his possession to that of his predecessors-in-interest, but he failed to present witnesses to substantiate this claim. The Court emphasized that bare assertions of possession by predecessors-in-interest are mere conclusions of law, not factual evidence. The burden of proof rests on the applicant to establish compliance with Section 48(b) of Commonwealth Act No. 141, as amended, by clear and convincing evidence, a burden petitioner failed to discharge. The Court deferred to the appellate court's findings of fact, which were supported by the record. On the CA's decision to reverse the RTC: Therefore, the CA did not err in reversing the RTC's decision and dismissing the application.
Main Doctrine
An applicant for confirmation and registration of imperfect title must prove by clear and convincing evidence that the land is alienable and disposable public land and that they, or their predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession and occupation thereof under a bona fide claim of ownership since June 12, 1945, or earlier.