Republic v. Santos
REITERATIONFacts
1. The Antecedents: Respondents Francisca, Geronimo, and Crispin Santos filed an application for the registration of title for four parcels of land located in Taguig, specifically Lot Nos. 536, 1101, 1214, and 1215. They submitted the required survey plans, technical descriptions, surveyor's certificate, tax declaration, and deed of extrajudicial settlement. Subsequently, their brother, Eusebio Santos, intervened and was included as a co-applicant. Later, the applicants withdrew the application concerning Lot No. 536. 2. Procedural History: The Regional Trial Court (RTC), after the applicants presented their evidence ex-parte, ordered the registration of the remaining properties in the names of the respondents on April 19, 2006. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Court of Appeals (CA). Despite notice, the respondents failed to submit an appellee's brief. The CA, on July 15, 2009, affirmed the RTC's decision in toto. A motion for reconsideration filed by the petitioner was denied by the CA on March 8, 2010. 3. The Petition: The Republic of the Philippines filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. The petitioner argues that the respondents failed to present sufficient evidence to prove that the subject lots were declared alienable and disposable lands of the public domain at the time of the application, and that they had possessed the land for the legally required period. The petitioner contends that a mere certification from the DENR is insufficient and that a copy of the original classification approved by the DENR Secretary is required, which was not submitted.
Issue(s)
Whether the trial court and the CA were correct in finding that the subject lots had been declared alienable and disposable lands of the public domain at the time the application was filed. Whether the respondents had been in open, continuous, exclusive, and notorious possession of the land for the time required by law when they filed their application for registration.
Ruling
The petition is GRANTED. The Decision dated July 15, 2009, of the Court of Appeals in CA-G.R. CV No. 90135 is SET ASIDE. The application for registration filed by respondents Francisca, Geronimo and Crispin, all surnamed Santos, is DENIED.
Ratio Decidendi
On the issue of whether the subject lots were declared alienable and disposable lands: The Court ruled in favor of the petitioner. The Court reiterated the Regalian doctrine that all lands of the public domain belong to the State. To overcome the presumption that land sought to be registered is part of the public domain, an applicant must prove that the land is alienable and disposable through positive acts of the government. Such proof can consist of a presidential proclamation, an executive order, an administrative action, investigation reports of Bureau of Lands investigators, or a legislative act or statute. While a certification from the DENR, PENRO, or CENRO may be obtained, it is not sufficient by itself. The applicant must also present a copy of the original classification approved by the DENR Secretary, certified as a true copy by the legal custodian of official records. In this case, the respondents failed to submit the required documents, relying only on a DENR certification and notations in survey plans, which are inadequate. Therefore, the application for registration must be denied due to insufficient proof of the alienable and disposable character of the land. On the issue of possession: While not explicitly ruled upon due to the failure to establish the alienable and disposable nature of the land, the Court's denial of the application based on the first issue renders this point moot. The requirement of proving possession for the required period is contingent upon first establishing that the land is alienable and disposable. Since the respondents failed to discharge their burden of proof on the latter, the application for registration could not prosper regardless of the length or nature of their possession.
Main Doctrine
An applicant for land registration must prove that the land subject of the application is alienable and disposable by establishing the existence of a positive act of the government, such as a presidential proclamation or an executive order, an administrative action, investigation reports of Bureau of Lands investigators, and a legislative act or a statute. A certification from the DENR, PENRO, or CENRO, by itself, is insufficient; a copy of the original classification approved by the DENR Secretary, certified as a true copy by the legal custodian of official records, must also be presented.