Armed Forces of the Philippines Retirement and Separation Benefits System v. Republic of the Philippines
REITERATIONFacts
The Antecedents: On July 10, 1997, the Armed Forces of the Philippines Retirement and Separation Benefits System (AFP-RSBS) filed an application for original registration of 48,151 square meters of land in Silang, Cavite, designated as Lot Nos. 2969-A, 2969-B, and 2969-C. AFP-RSBS alleged acquisition from Narciso Ambrad, Alberto Tibayan, and Restituto Tibayan on March 13, 1997, and claimed that its predecessors-in-interest had been in possession since June 12, 1945. Procedural History: The Municipal Circuit Trial Court approved AFP-RSBS’s application on July 28, 2001. The Republic of the Philippines moved for reconsideration, which was denied. The Republic appealed, citing improper identification of properties, noncompliance with administrative circulars, non-submission of a tracing cloth plan, and lack of DENR certification on alienability. The Court of Appeals reversed the trial court’s decision on January 10, 2007, dismissing the application. The CA found that while AFP-RSBS complied with some requirements, the land was declared alienable and disposable only on March 15, 1982. Therefore, the CA excluded possession prior to this date, finding that AFP-RSBS’s and its predecessors-in-interest’s possessions could not ripen into ownership. The CA also ruled that AFP-RSBS, as a private corporation, could not own alienable lands of the public domain. AFP-RSBS’s motion for reconsideration was denied on October 5, 2007. The Petition: AFP-RSBS filed a petition for review on certiorari before the Supreme Court.
Issue(s)
Whether the period of possession prior to the declaration that land is alienable and disposable agricultural land should be excluded from the computation of the period of possession for purposes of original registration. Whether AFP-RSBS, as a government-owned corporation, can acquire title to alienable lands of the public domain.
Ruling
The petition is GRANTED. The Court of Appeals' decision of January 10, 2007, and resolution of October 5, 2007, are SET ASIDE. The July 28, 2001 trial court decision is REINSTATED.
Ratio Decidendi
On the issue of computing the period of possession: The Supreme Court ruled that the period of possession prior to the declaration that land is alienable and disposable agricultural land is included in the computation of possession for purposes of acquiring registration rights over a property, provided that the land has already been declared as such at the time the application is filed. The Court clarified that Section 14(1) of the Property Registration Decree requires the property sought to be registered to be alienable and disposable at the time the application is filed. The Court emphasized that the date June 12, 1945, qualifies the requisite period of possession and occupation, and the law imposes no requirement that the land should have been declared alienable and disposable agricultural land as early as June 12, 1945. This interpretation aligns with the ruling in Republic v. Naguit and Heirs of Mario Malabanan v. Republic of the Philippines, which held that the contrary pronouncement in Republic v. Herbieto had no precedential value with respect to Section 14(1) due to its absurdly limiting application. The Court found that AFP-RSBS and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since before 1945, supported by testimonies and tax declarations. Therefore, their possession ripened into a registrable title. On the issue of AFP-RSBS's capacity to acquire title: The Supreme Court held that AFP-RSBS, being a government-owned and -controlled corporation, can acquire title to the property under Section 14(1) of the Property Registration Decree or Section 48(b) of the Public Land Act, and not through acquisitive prescription. The Court clarified that the prohibition in Section 3, Article XII of the Constitution against private corporations acquiring public land does not apply to government corporations like AFP-RSBS, which was organized under Presidential Decree No. 361, as amended. The type of corporation AFP-RSBS is has no bearing on the grant of its application for original registration.
Main Doctrine
The period of possession prior to the declaration that land is alienable and disposable agricultural land is included in the computation of possession for purposes of acquiring registration rights over a property if the land has already been declared as such at the time of the application for registration.