Republic v. Bibonia
REITERATIONFacts
The Antecedents: Respondents Cheryl B. Bibonia and Ricardo L. Fernandez (substituted by Joselito G. Manahan) filed an application for registration of two parcels of land. Respondent Bibonia’s application covered Lot 1, which she allegedly bought from Marita King, who received it from her father, Mariano Morales, by donation. Morales purchased it from Sisenando Barco, who bought it from Restituto Paraon in 1955. Respondent Manahan’s application covered Lot 2, which Ricardo L. Fernandez allegedly bought from Remedios Cribe, to whom it was donated by her father, Mariano Morales. Morales purchased it from Basilia Barco and the heirs of Liberato Salome in 1968. Procedural History: The Regional Trial Court (RTC) granted the application for registration, confirming the titles of the respondents. The Republic of the Philippines appealed. The Court of Appeals affirmed the RTC's decision in toto. The Petition: The Republic filed a Petition for Review on Certiorari, contending that the Court of Appeals erred in ruling that respondents occupied the lots for thirty years and that they could not have maintained a bona fide claim of ownership because the lots were declared alienable and disposable only eight years prior to the application filing. The Republic argued that the required possession should have been since June 12, 1945, or earlier.
Issue(s)
Whether respondents were able to prove that the lots subject of their application were then disposable and alienable land of the public domain. Whether respondents were able to show that they have been in open, exclusive, continuous and notorious possession of the lots in the concept of owners since June 12, 1945, or earlier.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED, and the respondents' application for registration of title is DENIED.
Ratio Decidendi
On the issue of whether the lots are alienable and disposable: The Court held that the requirement under Section 14(1) of P.D. No. 1529 is that the land must be alienable and disposable at the time the application for registration is filed. It is undisputed that the subject lots were declared alienable and disposable by the DENR on January 17, 1986, which was prior to the filing of the application in 1994. The Court rejected the petitioner's argument that this declaration being subsequent to June 12, 1945, invalidated the application, stating that such an interpretation would lead to an absurd situation where lands not declared alienable before June 12, 1945, would not be susceptible to registration despite long possession. The Court adopted the interpretation that the State's intention to release the property for alienation is evidenced by its classification as alienable and disposable at the time of application. On the issue of possession since June 12, 1945: The Court found that while the trial court and the Court of Appeals concluded that respondents and their predecessors-in-interest had been in open, exclusive, continuous, and notorious possession for over thirty years, this period of possession, even if more than 39 years at the time of application, does not satisfy the requirement under Section 14(1) of P.D. No. 1529, as amended by P.D. No. 1073. This provision requires possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. The evidence on record showed that the predecessors-in-interest had been in possession only since 1955. Therefore, the required statutory period of possession since June 12, 1945, was not met, despite the land being declared alienable and disposable at the time of application.
Main Doctrine
For purposes of land registration under Section 14(1) of P.D. No. 1529, applicants must prove that the land is alienable and disposable at the time of filing the application, and that they and their predecessors-in-interest have been in open, exclusive, continuous, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. Possession prior to the declaration of land as alienable and disposable, even if lengthy, does not suffice if it does not meet the June 12, 1945 requirement.