Republic v. Metro Index Realty
REITERATIONFacts
The Antecedents: Metro Index Realty and Development Corporation (respondent) filed an application for judicial confirmation of title over three parcels of land totaling 39,490 square meters in Indang, Cavite. The respondent claimed to have purchased these properties from the Sicap siblings, who inherited them from their parents. The respondent asserted that it and its predecessors-in-interest had been in possession of the properties for over fifty years, with tax declarations in their names since 1956, and that the land was alienable and disposable, supported by a DENR certification and affidavits from adjoining landowners. Procedural History: The application was filed with the Regional Trial Court (RTC), Naic, Cavite, which granted the respondent's application, finding the land to be alienable and disposable and that the possession by the applicant and its predecessors-in-interest was open, public, continuous, notorious, and adverse. The Republic of the Philippines appealed to the Court of Appeals (CA), which affirmed the RTC's decision, holding that the payment of taxes since 1956 and the presence of some trees, even if few, were sufficient to prove possession for the required period. The CA emphasized that ownership is not solely determined by the extent of cultivation and that possession can be constructive. The Petition: The Republic of the Philippines filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision. The petitioner argued that the respondent failed to prove compliance with either Section 14(1) or Section 14(2) of Presidential Decree No. 1529. Specifically, the petitioner contended that there was no evidence of possession commencing on June 12, 1945, or earlier as required by Section 14(1), and that the properties could not be acquired by prescription under Section 14(2) because there was no official declaration that they had become patrimonial property. The petitioner also argued that the CA erred in finding sufficient possession, as tax declarations alone are not conclusive proof of ownership, and the alleged cultivation was merely casual, not constituting possession under claim of ownership.
Issue(s)
Whether the respondent sufficiently proved its entitlement to the confirmation of imperfect title under P.D. No. 1529, considering the requirement of an express government declaration that the subject properties have become patrimonial. Whether the subject properties, once declared alienable and disposable, can be acquired by prescription without an express government declaration that they have become patrimonial. Whether the evidence presented by the respondent and its predecessors-in-interest constituted possession and occupation in the manner contemplated by law for purposes of acquiring title by prescription.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. The respondent's application for original registration of title is DENIED for lack of merit.
Ratio Decidendi
On the issue of acquiring title by prescription under Section 14(2) of P.D. No. 1529: The Court held that properties of the public dominion are not susceptible to prescription. Only properties of the State that are no longer earmarked for public use or development of national wealth, known as patrimonial property, may be acquired by prescription. Crucially, the prescriptive period for acquiring imperfect title over a property of the State commences only from the date an official declaration is issued that such property is no longer intended for public service or development of national wealth. Prescription will not run against the State even if the property has been previously classified as alienable and disposable; it is the official declaration that converts the property to patrimonial. The Court found no evidence of such an official declaration in this case, rendering the respondent's claim of acquisition by prescription untenable. The lower courts erred in assuming that a public land, once declared alienable and disposable, can be acquired by prescription without this essential governmental act. On the issue of acquiring title by prescription: The Court reiterated that prescription will not run against the State even if the property has been previously classified as alienable and disposable; it is the official declaration that converts the property to patrimonial. The Court found no evidence of such an official declaration in this case, rendering the respondent's claim of acquisition by prescription untenable. The lower courts erred in assuming that a public land, once declared alienable and disposable, can be acquired by prescription without this essential governmental act. On the issue of whether the respondent sufficiently proved possession and occupation: The Court found that the CA erred in downplaying the importance of demonstrating actual cultivation and development. While tax declarations are bases for inferring possession, they must be coupled with proof of actual possession. The Court noted that the number of trees (three santol, one avocado, and one star apple) was insignificant and did not demonstrate actual cultivation sufficient to establish possession under claim of ownership. This constituted mere casual cultivation, which does not satisfy the requirement of open, continuous, exclusive, and notorious possession. The doctrine of constructive possession, as applied by the CA, was deemed inappropriate without considering the size of the properties and the nature of the cultivation. The Court reiterated that possession under claim of ownership requires more than mere nominal claim or casual cultivation; it must not be a mere fiction and should involve acts of dominion of such a nature as a party would naturally exercise over his own property.
Main Doctrine
Properties of the public dominion, even if declared alienable and disposable, cannot be acquired by prescription unless there is an express government declaration that they are no longer intended for public service or development of national wealth, thereby converting them into patrimonial property. Mere possession and occupation, even if open, continuous, exclusive, and notorious for extended periods, are insufficient without such official declaration.