Republic v. Joson
REITERATIONFacts
The Antecedents: Respondent Rosario de Guzman Vda. de Joson filed an application for land registration of a riceland (Lot 2633, Cad-297, Paombong, Bulacan) with an area of 12,342 square meters. She claimed ownership and possession, along with her predecessors-in-interest, since 1907, openly, publicly, uninterruptedly, and adversely since 1963. Procedural History: The Court of First Instance (CFI) of Bulacan granted the application, finding that the respondent had sufficiently established open, public, continuous, and adverse possession in the concept of an owner for over 30 years. The Republic, through the Solicitor General, appealed to the Court of Appeals (CA), arguing that the land was unclassified forest land and thus not subject to registration. The CA affirmed the CFI's decision. The Republic then filed a petition for review on certiorari with the Supreme Court. The Petition: The Republic appealed the CA's decision, contending that the land was not susceptible to private acquisition and that the lower courts erred in granting the application.
Issue(s)
Whether or not the land subject of the application for registration is susceptible of private acquisition. Whether or not the trial court, as well as the Court of Appeals, erred in granting the application for registration.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals, dismissed the application for land registration, and directed the respondent to pay the costs of suit.
Ratio Decidendi
On the issue of whether the land is susceptible of private acquisition: The Court held that the applicant bears the burden of proving two requisites under Section 14(1) of Presidential Decree No. 1529: (1) that the land is alienable and disposable land of the public domain, and (2) that the applicant, by themselves or through their predecessors-in-interest, had been in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945, or earlier. While the respondent presented evidence of her and her predecessors' possession since 1926, thus satisfying the second requisite, she failed to discharge her burden of proving the land's classification as alienable and disposable. The Court emphasized that a mere certification from the Community Environment and Natural Resources Office (CENRO) is insufficient; an applicant must also present a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of official records. Furthermore, even if the land were declared alienable and disposable, the declaration must have been made prior to the filing of the application for registration. On the issue of whether the lower courts erred in granting the application: Even if the land were declared alienable and disposable, the declaration must have been made prior to the filing of the application for registration. In this case, the certification indicating the land's reclassification as alienable and disposable was dated October 15, 1980, which was after the application was filed in 1976, rendering it ineffective for the purpose of registration under Section 14(1). Regarding Section 14(2), which pertains to ownership acquired by prescription, the Court reiterated that property of public dominion, even if declared alienable and disposable, cannot be acquired by prescription unless there is an express declaration by the State that it is no longer intended for public service or development of national wealth, converting it into patrimonial property. The period of possession prior to such conversion cannot be counted for purposes of prescription. Since no such express declaration was made, and the land was not proven to have been converted into patrimonial property, ownership by prescription could not be acquired. Therefore, the application for registration was dismissed.
Main Doctrine
An applicant for land registration bears the burden of proving that the land is alienable and disposable and that possession commenced on or before June 12, 1945. Possession of public land, even if long-standing, cannot ripen into ownership by prescription unless there is a positive act of the State declaring the land alienable and disposable and no longer intended for public service or development of national wealth, and such declaration must precede the commencement of acquisitive prescription.