Republic v. Rizalvo
REITERATIONFacts
The Antecedents: Respondent Teodoro P. Rizalvo, Jr. filed an application for registration of an 8,957-square meter parcel of land in Bauang, La Union. He claimed ownership by virtue of a Deed of Transfer dated December 31, 1962, from his mother, Bibiana P. Rizalvo, and asserted possession, supported by tax declarations and tax payment receipts. His mother testified to purchasing the land in 1952 and possessing it. A Land Investigator's report confirmed the land was within the alienable and disposable zone and the applicant was in possession. Procedural History: The Municipal Trial Court (MTC) of Bauang, La Union, approved the application. The Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed to the Court of Appeals (CA). The CA affirmed the MTC decision. The Republic then filed a petition for review on certiorari with the Supreme Court. The Petition: The OSG argued that the respondent failed to prove a registrable title, specifically that he and his predecessors-in-interest had not been in open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The OSG contended that tax declarations and receipts are insufficient evidence of ownership and that the property remained part of the public domain.
Issue(s)
Whether the respondent proved compliance with the requirements for judicial confirmation of imperfect title under Section 14(1) of P.D. No. 1529. Whether the respondent is entitled to registration of title by acquisitive prescription under Section 14(2) of P.D. No. 1529.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. The respondent's application for registration is DENIED.
Ratio Decidendi
On the requirements for judicial confirmation of imperfect title under Section 14(1) of P.D. No. 1529: The Court found that while the first requirement, that the land is alienable and disposable, was satisfied by the DENR-CENRO certification, and the second requirement, regarding open, continuous, exclusive, and notorious possession and occupation, was affirmed by the lower courts and binding on the Supreme Court absent glaring errors, the third requirement was not met. The respondent failed to prove open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. The evidence presented, including a Deed of Absolute Sale dated July 8, 1958, a 1948 Tax Declaration in the name of a predecessor, and tax payment receipts starting in 1952, only established possession and claim of ownership from 1948, which is insufficient to meet the statutory requirement of possession dating back to June 12, 1945, or earlier. On entitlement to registration by acquisitive prescription under Section 14(2) of P.D. No. 1529: The Court ruled that even if the respondent's possession exceeded thirty years, he was not entitled to registration by prescription. Jurisprudence clarifies that the thirty-year period for acquiring ownership and registering public land under Section 14(2) only begins from the moment the State expressly declares that the public dominion property is no longer intended for public service or the development of the national wealth, or has been converted into patrimonial property. Such a declaration must be in the form of a law enacted by Congress or a Presidential Proclamation. The DENR-CENRO certification, stating the land is within the alienable and disposable zone since January 21, 1987, is not an express declaration by the State that the land is no longer intended for public service or development. Furthermore, even if this certification were considered sufficient, the application was filed in 2000, only thirteen years after 1987, falling short of the required thirty years for acquisitive prescription.
Main Doctrine
An applicant for judicial confirmation of imperfect title must prove that the land is alienable and disposable, that the applicant and predecessors-in-interest possessed it openly, continuously, exclusively, and notoriously under a bona fide claim of ownership since June 12, 1945, or earlier. For acquisitive prescription under Section 14(2) of P.D. No. 1529, the thirty-year period begins only from the State's express declaration that the public dominion property is no longer intended for public service or development of national wealth.