Republic v. Consunji
REITERATIONFacts
The Antecedents: Respondent Fredesvinda Almeda Consunji filed an application for original registration of title over Lot Nos. 1399, 2232, and 2601, all of Cad-424, Sto. Tomas Cadastre, before the RTC of Tanauan, Batangas. Respondent claimed ownership in fee simple by virtue of inheritance and possession, stating she acquired the lands from her deceased uncle, Claro T. Almeda, through his Last Will and Testament. She asserted continuous, peaceful, exclusive, public, and adverse possession with her predecessors-in-interest for over 60 years. Procedural History: The RTC granted the application, adjudicating the lots to respondent. The Republic of the Philippines appealed to the Court of Appeals (CA), arguing that respondent failed to establish the required period of possession and to overcome the presumption that the properties are part of the public domain. The CA affirmed the RTC's decision. Hence, the Republic filed a petition for review on certiorari with the Supreme Court. The Petition: The Republic contended that the CA erred in finding that respondent established the required possession period, in considering tax declarations as evidence of possession, and in relying on the CENRO certification as proof of the land's alienable and disposable character.
Issue(s)
Whether the Court of Appeals erred in finding that the respondent has established possession over the subject properties for the period required by law. Whether the Court of Appeals erred in considering the tax declarations as evidence of respondent’s possession. Whether the Court of Appeals erred in considering the certification by the CENRO as proof of its alienable and disposable character.
Ruling
The petition is DENIED. The Court AFFIRMS the July 1, 2003 Decision of the Court of Appeals and the April 14, 2000 Decision of the Regional Trial Court, granting respondent's application for original registration of title over Lot Nos. 1399, 2232, and 2601.
Ratio Decidendi
On the issue of established possession for the required period: The Court held that the findings of fact of the trial court, especially when affirmed by the appellate court, are accorded high respect and are generally conclusive. While the respondent's possession commenced in 1978 upon inheritance, she was able to tack her possession to that of her predecessor-in-interest, Claro T. Almeda. The testimony of Andres Sanchez, an adjacent landowner who was born in 1930, was crucial. Sanchez testified that he knew Claro Almeda since he was ten years old (around 1940) and observed the lands planted with rice, corn, citrus, and coconut trees, indicating possession and occupation even before June 12, 1945. Sanchez also testified that no other person claimed interest in the properties adverse to Almeda and later to respondent. The Court found Sanchez's testimony significant and credible in substantiating the claim of possession since before the statutory period. The Court reiterated that the requirement under Section 14(1) of P.D. No. 1529 and Section 48(b) of C.A. No. 141 is possession and occupation since June 12, 1945, or earlier, under a bona fide claim of ownership. On the issue of tax declarations as evidence of possession: The Court reiterated the established rule that while tax declarations are not conclusive proof of ownership, they are competent evidence to show a claim of title and serve as a basis for inferring possession. The Court noted that the earliest tax declarations presented dated back to 1955, which is after the required June 12, 1945 period. However, citing Recto v. Republic, the Court held that belated tax declarations do not necessarily negate possession that commenced earlier. The credibility of testimony supporting possession for the required period is paramount. Therefore, the tax declarations, when corroborated by credible testimony, bolster the respondent's claim of possession by her predecessor-in-interest prior to 1945. On the issue of CENRO certification as proof of alienable and disposable character: The Court found no error in the CA's reliance on the Certification from the DENR Regional Technical Director. This certification explicitly stated that the subject lots fall within Alienable and Disposable Project No. 30 of Sto. Tomas, Batangas, per L.C. Map 582 dated December 25, 1925. The Court considered this a positive government act declaring the land as alienable and disposable. Such a certification, in the absence of contradictory evidence, enjoys a presumption of regularity and is sufficient to establish the nature and character of the properties. The Court noted that the petitioner's argument that the issuing officer should have testified was not a valid ground to disregard the certification, especially since it was presented as evidence by the respondent.
Main Doctrine
The testimony of a credible witness who has personal knowledge of the land and its ownership and possession since before June 12, 1945, coupled with documentary evidence such as tax declarations and certifications from government agencies declaring the land as alienable and disposable, is sufficient to establish an applicant's right to original registration of title, even if the applicant's possession commenced only later, by tacking it to that of the predecessor-in-interest.