Republic v. Bautista
REITERATIONFacts
The Antecedents: Apolonio Bautista, Sr. acquired Lot 17078 of Cad. 547-D, Subic Cadastre, from Mario Jardin on February 15, 1971, and Cornelia Villanueva on May 25, 1973. He declared the property for taxation purposes and was its sole and exclusive possessor and occupant from acquisition until his death in 1987. His children, including respondent Apolonio Bautista, Jr., inherited the property. Apolonio, Jr. was later declared the sole owner through an extra-judicial settlement and had the property declared for taxation in his name. Procedural History: On October 21, 1996, Apolonio, Jr. filed an application for judicial confirmation of title in the Municipal Trial Court (MTC) of Subic, Zambales. He testified that his father had been in possession since 1969 and acquired the land through deeds of sale in 1971 and 1973, and had paid taxes. The Government did not object to his testimony or documentary evidence. The MTC granted the application. The Court of Appeals (CA) affirmed the MTC decision, noting the Government's failure to object to the evidence and testimony. The Petition: The Government appealed to the Supreme Court, arguing that Apolonio, Jr.'s testimony on possession was hearsay and lacked probative value. It contended that the alienation of public land requires careful scrutiny and that the required possession must be "since June 12, 1945, or earlier" under Section 48(b) of Commonwealth Act No. 141, as amended by Presidential Decree No. 1073. The Government also argued that tax declarations and receipts are insufficient to prove ownership in fee simple and that Apolonio, Jr.'s reliance on hearsay evidence showed his unfitness to own the land.
Issue(s)
Whether the testimony of Apolonio Bautista, Jr. regarding his father's possession of the land, being hearsay, has probative value. Whether Apolonio Bautista, Jr. and his predecessors-in-interest possessed the land since June 12, 1945, or earlier, as required by law for judicial confirmation of imperfect title. Whether tax declarations and tax receipts are sufficient to prove ownership in fee simple.
Ruling
The Court grants the petition for review on certiorari, reverses and sets aside the decision of the Court of Appeals, and dismisses the application of Apolonio Bautista, Jr. for judicial confirmation of his imperfect title.
Ratio Decidendi
On the issue of hearsay testimony: The Court held that even if the Government did not timely object to the admission of Apolonio, Jr.'s testimony, it had no probative value if he had no personal knowledge of the facts establishing the possession of the property for the requisite period. The Court emphasized that it was one thing for the trial court to admit evidence, but quite another to give it worth for judicial adjudication. Apolonio, Jr.'s admission of lacking personal or direct competence to know the truth of his assertion underscored the weakness of the evidence on possession. On the required period of possession: The Court reiterated that Section 48(b) of Commonwealth Act No. 141, as amended by Presidential Decree No. 1073, and Section 14(1) of Presidential Decree No. 1529 require possession and occupation of alienable and disposable lands of the public domain under a bona fide claim of ownership "since June 12, 1945, or earlier." The Court noted that Presidential Decree No. 1073, effective January 25, 1977, changed the required period from "thirty (30) years immediately preceding the filing of the application" to the June 12, 1945 benchmark. Based on the records, Apolonio, Jr. failed to establish that his father's possession, or his own, met this stringent requirement. He did not present witnesses who could attest to the possession of his predecessors-in-interest within the required timeframe, especially considering he only arrived in the Philippines in November 1987. On the sufficiency of tax declarations and receipts: While not explicitly ruled upon as a separate issue, the Court implicitly found that tax declarations and receipts alone were insufficient to prove ownership in fee simple, as the primary failure was the lack of proof of possession for the statutory period. The Court stressed that only the title of those who had possessed and occupied alienable and disposable lands of the public domain within the requisite period could be judicially confirmed, as such possession converts the land to private property by the mere lapse of the period.
Main Doctrine
The applicant for judicial confirmation of imperfect title must prove possession of the subject land since June 12, 1945, or earlier, as required by Section 48(b) of Commonwealth Act No. 141, as amended by Presidential Decree No. 1073, and Section 14(1) of Presidential Decree No. 1529. Hearsay testimony, even if not objected to, has no probative value to establish such possession.