Republic v. Roasa
REITERATIONFacts
The Antecedents: Respondent Cecilia Grace L. Roasa, represented by her attorneys-in-fact, filed an application for registration of title over a parcel of land (Lot 2) with the RTC of Tagaytay City. Respondent alleged ownership in fee simple, acquisition by purchase via a Deed of Absolute Sale dated December 2, 1994, and open, continuous, exclusive, and uninterrupted possession and occupation under a bona fide claim of ownership since the 1930s. The land was planted with various crops by respondent and her predecessors-in-interest, and they had declared the land for taxation purposes. Procedural History: The Republic of the Philippines, through the OSG, opposed the application, arguing that tax declarations and receipts were insufficient evidence of acquisition and possession, and that the lot was part of the public domain not subject to private appropriation. The RTC denied the application, finding that the evidence showed the land was not classified as forest land prior to March 15, 1982, and thus fell short of the required 30-year adverse possession period. The CA reversed the RTC decision, granting the application and directing the Register of Deeds to issue title in the respondent's name, holding that the possession requirement of June 12, 1945, was met and the land was alienable and disposable at the time of application. The Petition: The Republic filed a petition for review on certiorari, contending that possession prior to the declaration of the land as alienable and disposable on March 15, 1982, should be excluded from the computation of the 30-year period.
Issue(s)
Whether possession of a parcel of land prior to its declaration as alienable and disposable can be included in the computation of the period of possession required for the confirmation of imperfect title. Whether the respondent and her predecessors-in-interest complied with the requirements for the confirmation of imperfect title under Section 14(1) of Presidential Decree No. 1529 and Section 48(b) of Commonwealth Act No. 141.
Ruling
The petition is DENIED. The Decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the inclusion of possession prior to declaration of alienability: The Court held that possession of land prior to its declaration as alienable and disposable can be included in the computation of the period of possession for purposes of registration. This is based on the interpretation of Section 14(1) of the Property Registration Decree, as clarified in Republic v. Naguit and Heirs of Malabanan v. Republic of the Philippines. The crucial requirement is that the land must be declared alienable and disposable at the time of the application for registration. The date June 12, 1945, qualifies the requisite period of possession and occupation, not the date of declaration of alienability. The Court emphasized that the contrary pronouncement in Republic v. Herbieto has no precedential value with respect to Section 14(1) because it would lead to an absurd situation where lands not declared alienable before June 12, 1945, would be excluded from registration regardless of long-standing possession. On compliance with requirements for confirmation of imperfect title: The Court affirmed the CA's finding that the respondent complied with the requirements. There was no dispute that the subject lot was declared alienable and disposable on March 15, 1982, which was prior to the application for registration filed on December 15, 2000. Furthermore, the unchallenged testimonies of respondent's witnesses established that the respondent and her predecessors-in-interest had been in adverse, open, continuous, and notorious possession in the concept of an owner even before June 12, 1945. This satisfied the requirement of open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier, coupled with the land being alienable and disposable at the time of application.
Main Doctrine
Possession of land prior to its declaration as alienable and disposable can be credited towards the required period for confirmation of imperfect title, provided that the land is declared alienable and disposable at the time of the application for registration and the possession has been open, continuous, exclusive, and notorious under a bona fide claim of ownership since June 12, 1945, or earlier.