Republic v. Rayos del Sol
REITERATIONFacts
The Antecedents: Respondents filed an application for land registration under Section 14(1) of P.D. No. 1529 for Lot 8173-A, alleging they inherited it from their father, Jose, who inherited it from his father, Felipe. They claimed open, continuous, exclusive, and notorious possession and occupation of alienable and disposable land of the public domain under a bona fide claim of ownership since the 1930s. They presented an Extra-judicial Settlement of the Estate of Felipe Rayos Del Sol, where Lot 8173-A was adjudicated to them pro indiviso. They also presented tax declarations dating back to 1948 and a Deed of Absolute Sale for a portion of the lot (Lot 8173-A-2) sold to the Republic of the Philippines through the DPWH. Procedural History: The Regional Trial Court (RTC), Branch 271, Pasig City, granted the application for land registration, confirming the title of the respondents. The Republic moved for reconsideration, which was denied. The Court of Appeals (CA) affirmed the RTC's decision, finding sufficient evidence of open, exclusive, continuous, and notorious possession and occupation under a bona fide claim of ownership since the 1930s. The Republic's motion for reconsideration was also denied. The Petition: The Republic, through the Office of the Solicitor General (OSG), filed a petition for review on certiorari before the Supreme Court, arguing that respondents failed to prove possession since June 12, 1945, that tax declarations are inconclusive, that the testimonies were general, and that the deed of sale pertained to a different lot.
Issue(s)
WHETHER OR NOT RESPONDENTS WERE ABLE TO ESTABLISH THE REQUIREMENTS SET IN SECTION 14 OF P.D. NO. 1529 AND THAT SHE AND HER PREDECESSORS-IN-INTEREST HAVE BEEN IN OPEN, CONTINUOUS, EXCLUSIVE AND NOTORIOUS POSSESSION AND OCCUPATION OF THE SUBJECT PROPERTY FOR THE PERIOD REQUIRED BY LAW.
Ruling
The petition is DENIED. The September 25, 2013 Decision and the February 25, 2014 Resolution of the Court of Appeals in CA-G.R. CV No. 96654 are AFFIRMED in toto.
Ratio Decidendi
On Issue 1: The Supreme Court affirmed that respondents were able to establish the requirements under Section 14(1) of P.D. No. 1529, proving open, continuous, exclusive, and notorious possession and occupation of the subject property for the period required by law. The Court initially noted that the OSG's arguments presented questions of fact, which are generally beyond the scope of a Rule 45 petition. However, even applying procedural liberality, the Court found that both the Court of Appeals and the Regional Trial Court properly appreciated the evidence. The Court reiterated that while tax declarations alone are not conclusive evidence of ownership, they serve as a strong basis for inferring possession and strengthen a bona fide claim of acquisition of ownership, as held in Mistica v. Republic. The Court also cited Recto v. Republic and Spouses Llanes v. Republic, which held that even if the earliest tax declaration is not dated June 12, 1945, or earlier, an application may still be granted if the evidence, taken as a whole, establishes open, continuous, exclusive, and notorious possession in the concept of an owner on or before June 12, 1945. The testimonies of Lydia Rayos del Sol-Alcantara and Gloria Serviño, which detailed the cultivation of the land by Felipe Del Sol since the 1930s, followed by Jose Rayos Del Sol and then the respondents through a caretaker, sufficiently established possession prior to June 12, 1945, and its open, continuous, exclusive, and notorious character. Furthermore, the Extrajudicial Settlement of the Estate of Felipe Rayos Del Sol confirmed the property's inclusion in Felipe's estate and its adjudication to respondents, while the Deed of Absolute Sale to the Department of Public Works and Highways for a portion of the subdivided Lot 8173-A-2 served as an acknowledgment by the Republic of respondents' ownership claim over the property, supporting their allegations of possession. The Court found that the OSG failed to present any evidence to disprove or contradict the claims of respondents, thus satisfying the burden of proof for the application.
Main Doctrine
The Court affirmed the grant of land registration under Section 14(1) of P.D. No. 1529, holding that testimonial and documentary evidence, including tax declarations, when taken as a whole, can sufficiently establish open, continuous, exclusive, and notorious possession and occupation of alienable and disposable land of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier, even if the earliest tax declaration predates the required period.