Republic v. Diloy
REITERATIONFacts
The Antecedents: Respondent Gregoria L. Diloy filed an application for registration of title over a parcel of land located in Barangay Dagatan, Municipality of Amadeo, Province of Cavite, with an area of 22,249 square meters. The subject property was declared for taxation purposes as early as 1948 by Crispin Leaban, succeeded by Eusebio Leaban, then by Pacencia Leaban, who conveyed the property to the respondent via a Deed of Absolute Sale on June 15, 1979. The respondent, married to Joselito C. Espiritu, filed the application in 1997 under Section 14 of Presidential Decree No. 1529. Procedural History: The Municipal Circuit Trial Court (MCTC) granted the application. The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed the application, arguing that the respondent failed to prove the required period of possession. The MCTC denied the Republic's Motion for Reconsideration. The Court of Appeals affirmed the MCTC's decision. The Republic's subsequent Motion for Reconsideration was also denied, leading to the present Petition for Review on Certiorari. The Petition: The Republic argues that the respondent failed to comply with the period of possession required by Section 14 of Presidential Decree No. 1529, as the subject property was declared alienable and disposable only on March 15, 1982. From 1982 to 1997, the respondent's adverse possession was only 15 years, falling short of the 30-year requirement. The Republic contends that the respondent did not acquire an imperfect title because the property was not alienable and disposable on June 12, 1945, and the possession lacked the required number of years for prescription.
Issue(s)
Whether the respondent has acquired a registrable title to the subject property. Whether the respondent and her predecessors-in-interest complied with the requirements of Section 14 of Presidential Decree No. 1529 for the confirmation of imperfect title.
Ruling
The petition is granted. The Decision and Resolution of the Court of Appeals affirming the MCTC's decision are reversed and set aside. The respondent's Application for Registration of Title over the subject property is denied.
Ratio Decidendi
On the issue of whether the respondent has acquired a registrable title to the subject property: The Court held that while the respondent and her predecessors-in-interest were in open, continuous, exclusive, and notorious possession of the subject property, they failed to prove that such possession was under a bona fide claim of ownership since June 12, 1945, or earlier. The respondent's possession commenced in 1979, and her predecessors-in-interest declared the property for taxation only in 1948, which was short of three years from the required reckoning date of June 12, 1945. Crucially, the subject property was declared alienable and disposable only on March 15, 1982. Therefore, the period of possession prior to this declaration could not be counted towards the acquisition of ownership or an imperfect title. On the issue of whether the respondent and her predecessors-in-interest complied with the requirements of Section 14 of Presidential Decree No. 1529 for the confirmation of imperfect title: The Court reiterated the three requisites for filing an application for registration of title under Section 14(1) of P.D. 1529: (1) the property must be alienable and disposable land of the public domain; (2) the applicants, by themselves or through their predecessors-in-interest, must have been in open, continuous, exclusive, and notorious possession and occupation; and (3) such possession must be under a bona fide claim of ownership since June 12, 1945, or earlier. The Court emphasized that Section 14(1) requires the property to be alienable and disposable at the time the application is filed. In this case, the property was declared alienable and disposable on March 15, 1982. Consequently, any possession prior to this date could not be considered adverse possession that could ripen into ownership. The possession from 1982 to 1997, when the application was filed, amounted to only 15 years, which is insufficient to meet the 30-year requirement for prescription or the confirmation of an imperfect title. The Court applied the maxim 'Dura lex sed lex' (The law is harsh, but it is the law).
Main Doctrine
Possession of public land, even if open, continuous, exclusive, and notorious, cannot ripen into ownership or an imperfect title that can be confirmed by judicial proceedings unless the land has been declared alienable and disposable. Any period of possession prior to the classification of the land as alienable and disposable is inconsequential and should be excluded from the computation of the required period of possession.