Republic v. Iglesia Ni Cristo
REITERATIONFacts
The Antecedents: Iglesia Ni Cristo (INC), represented by its Executive Minister Eraño G. Manalo, filed an Application for Registration of Title over Lot No. 3946 of the Currimao Cadastre before the Municipal Circuit Trial Court (MCTC). The lot, with an area of 4,201 square meters, was described as situated in Barrio Baramban, Municipality of Currimao, Province of Ilocos Norte. Appended to the application were the plan, technical description, Geodetic Engineer’s Certificate, Tax Declaration, and a Deed of Sale dated September 7, 1970, executed by Bernardo Badanguio in favor of INC. Procedural History: The Republic of the Philippines, through the Office of the Solicitor General (OSG), filed an Opposition to INC's application. After publication, notification, and posting, the MCTC, acting as a cadastral court, rendered a Decision on April 26, 2005, granting INC's application. The MCTC found that INC had complied with the essential requisites for judicial confirmation of an imperfect title, establishing continuous possession for over 40 years. The Republic appealed to the Court of Appeals (CA). On October 11, 2007, the CA affirmed the MCTC Decision in toto, finding that the documentary and testimonial evidence sufficiently established INC's continuous, open, and peaceful possession and occupation in the concept of an owner for more than 40 years, including the possession of its predecessors-in-interest. The Petition: The Republic filed a Petition for Review on Certiorari under Rule 45, assailing the CA Decision. The Republic's main contention is that the CA erred in affirming the MCTC Decision because the land was declared alienable and disposable only on May 16, 1993, which was five years before the filing of the application on November 19, 1998. The Republic argued that possession prior to the declaration of alienability is inconsequential and that INC's possession fell short of the 30-year period required under Section 48(b) of Commonwealth Act No. 141 (Public Land Act).
Issue(s)
Whether the Court of Appeals erred on a question of law in affirming the MCTC Decision granting the application for land registration despite evidence that the land was declared alienable and disposable land of the public domain only on May 16, 1993, or five (5) years before the filing of the application for registration on November 19, 1998; specifically, whether the five-year period is sufficient for judicial confirmation of imperfect title. Whether judicial confirmation of imperfect title can prosper when the subject property has been declared as alienable and disposable only after June 12, 1945; specifically, addressing the nature of possession required and the applicability of Republic v. Herbieto.
Ruling
The petition is bereft of merit. The Supreme Court denied the petition and affirmed the decision of the Court of Appeals in toto.
Ratio Decidendi
On the issue of whether the Court of Appeals erred on a question of law in affirming the MCTC Decision granting the application for land registration despite evidence that the land was declared alienable and disposable land of the public domain only on May 16, 1993, or five (5) years before the filing of the application for registration on November 19, 1998: The Court reiterated the doctrine established in Republic v. Court of Appeals (Naguit), which was later affirmed in Heirs of Mario Malabanan v. Republic. The prevailing interpretation of Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree) is that it merely requires the property sought to be registered to be alienable and disposable at the time the application for registration of title is filed. The Court clarified that the phrase "since June 12, 1945" in Section 14(1) qualifies the antecedent phrase "under a bona fide claim of ownership," not the alienable and disposable character of the land. Therefore, possession prior to the declaration of alienability is counted towards the required period of possession, as long as the land is declared alienable and disposable at the time of the application. The Court emphasized that as a rule, the findings of fact of the trial court, when affirmed by the CA, are final and conclusive and cannot be reviewed on appeal by the Supreme Court, provided they are borne out by the record or based on substantial evidence. The Supreme Court's jurisdiction is limited to reviewing errors of law. In this case, the factual findings regarding INC's possession and occupation were consistently upheld by both the MCTC and the CA. On the issue of whether judicial confirmation of imperfect title can prosper when the subject property has been declared as alienable and disposable only after June 12, 1945: The Court noted that the pronouncement in Republic v. Herbieto, which held that possession prior to the declaration of alienability is inconsequential, was considered obiter dictum because the land registration proceedings in that case were void ab initio due to lack of publication. The Court explicitly stated that the ruling in Herbieto was abandoned in favor of the more reasonable interpretation in Naguit and Malabanan. The stringent interpretation in Herbieto would render Section 14(1) virtually inoperative and stifle the State's policy of encouraging the distribution of alienable public lands. The Court found no error in the findings of the lower courts that INC had sufficiently established its possession and occupation of the subject lot in accordance with the Public Land Act and Section 14(1) of PD 1529. The possession of INC, which began with its purchases in 1952 and 1959, was tacked on to the possession of its predecessors-in-interest, Dionisio Sabuco and Bernardo Badanguio. Sabuco possessed the lot even before June 12, 1945, as he inherited it from his parents. These possessions were established to be open, continuous, exclusive, and notorious, under a bona fide claim of ownership, and were never disturbed. The Court reiterated the well-settled principle that no public land can be acquired by private persons without a grant, express or implied, from the government. It is indispensable for claimants to show that their title was acquired from the State or by any other mode recognized by law. In this case, the subject lot was declared alienable and disposable by the government on May 16, 1993, and INC filed its application on November 19, 1998, thus satisfying the requirement that the property be alienable and disposable at the time of application.
Main Doctrine
The property sought to be registered under Section 14(1) of PD 1529 (Property Registration Decree) must be alienable and disposable at the time the application for registration is filed. Possession prior to the declaration of alienability is counted towards the required period of possession.