Republic v. Remman Enterprises
REITERATIONFacts
The Antecedents: Remman Enterprises, Inc. (respondent) filed an application for judicial confirmation of title over two parcels of land, Lot Nos. 3068 and 3077, located in Barangay Napindan, Taguig, Metro Manila. The respondent claimed ownership and possession of these lands, asserting that they and their predecessors-in-interest had been in open, continuous, exclusive, and notorious possession since before June 12, 1945. The Laguna Lake Development Authority (LLDA) opposed the application, arguing that the parcels of land are part of the Laguna de Bay bed due to their elevation being below the reglementary level of 12.50 meters. The Republic of the Philippines also opposed, primarily on the grounds that the respondent failed to prove the required length and nature of possession and that the lands are alienable and disposable. Procedural History: The application was filed with the Regional Trial Court (RTC) of Pasig City, Branch 69. After an initial hearing where a general default was declared except for the LLDA, both the LLDA and the Republic filed oppositions. Following trial, the RTC granted the respondent's application, finding that the properties were indeed alienable and disposable and that the respondent had sufficiently proven possession. The Republic appealed this decision to the Court of Appeals (CA). The CA affirmed the RTC's ruling, agreeing that the respondent had established the alienable and disposable nature of the land and had met the possession requirements. The Republic then filed the present petition for review on certiorari with the Supreme Court. The Petition: The petitioner, the Republic of the Philippines, seeks review under Rule 45 of the Rules of Court, arguing that the CA erred in affirming the RTC's decision. The core of the petitioner's argument is that the respondent failed to present incontrovertible evidence to prove that the subject properties are alienable and disposable lands of the public domain. Specifically, the petitioner contends that the certifications from the DENR were insufficient and that the respondent did not present a copy of the original classification approved by the DENR Secretary. Furthermore, the petitioner argues that the respondent's evidence of possession, primarily the testimony of a caretaker, was unsubstantiated and lacked the specificity required to establish open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The petitioner also disputes the respondent's claim that the tax declarations, only starting in 2002, support their alleged long-standing possession.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court Decision which granted the application for registration filed by the respondent. Whether the respondent sufficiently proved that the subject properties are alienable and disposable lands of the public domain. Whether the respondent sufficiently proved that it and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the subject properties since June 12, 1945, or earlier.
Ruling
The petition is meritorious. The Supreme Court reversed and set aside the decision of the Court of Appeals and denied the application for registration of Remman Enterprises, Inc. for lack of merit.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the Regional Trial Court Decision which granted the application for registration filed by the respondent: The Supreme Court found that the lower courts erred in granting the application. While the lower courts correctly determined that the subject properties are not part of the Laguna Lake bed based on their elevations being above 12.50 m, this finding alone does not automatically mean the lands are alienable and disposable. The burden remains with the applicant to prove, with well-nigh incontrovertible evidence, that the lands are indeed alienable and disposable. The Court reiterated the Regalian Doctrine, emphasizing that all lands not appearing to be clearly within private ownership are presumed to belong to the State. Therefore, to overcome this presumption, the applicant must present sufficient proof of the land's alienable and disposable status. On the issue of whether the respondent sufficiently proved that the subject properties are alienable and disposable lands of the public domain: The Supreme Court ruled that the respondent failed to satisfy this requirement. The certifications from the DENR, while presented, were deemed insufficient. Citing Republic v. T.A.N. Properties, Inc. and Republic v. Roche, the Court clarified that an applicant must present not only a certification of alienability and disposability but also a copy of the original classification approved by the DENR Secretary, certified as a true copy by the legal custodian of records. The respondent failed to present such crucial documentary evidence. The Court also held that the ruling in T.A.N. Properties applies retroactively as it is an interpretation of existing law, not a new law. On the issue of whether the respondent sufficiently proved that it and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the subject properties since June 12, 1945, or earlier: The Supreme Court found that the respondent also failed to substantiate this claim. The testimony of the caretaker, Cerquena, regarding possession since 1943 and subsequent sales was considered unsubstantiated and self-serving. The Court emphasized that mere general statements are insufficient; specific acts of dominion are required. The alleged cultivation of crops lacked specificity regarding the nature, volume, or produce, and could be considered mere casual cultivation, not possession under a claim of ownership. Furthermore, the tax declarations presented were only for 2002, which, despite being proof of claim of ownership, created a presumption that such claim began in 2002, contradicting the claimed possession since 1943. The absence of declared improvements or plantings in the tax declarations also belied the claim of continuous possession.
Main Doctrine
To prove that land is alienable and disposable, an applicant for land registration must present not only a certification from the DENR but also a copy of the original classification approved by the DENR Secretary, certified by the legal custodian thereof as a true copy. Furthermore, the applicant must prove open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier, with well-nigh incontrovertible evidence.