Republic v. Mendiola
REITERATIONFacts
The Antecedents: Respondents, claiming to be heirs of the original owners, filed an application for land registration over a parcel of land situated in Barangay Ibayo, Tipas, Taguig, Metro Manila. They asserted continuous possession of the property in the concept of an owner since before June 17, 1945. Procedural History: The application was initially filed before the Regional Trial Court (RTC) of Pasig City. After a general default was declared against all oppositors except the petitioner, the RTC, upon presentation of evidence including a conversion survey plan, tax declarations, and a DENR certification, confirmed the respondents' title to the property. The Republic of the Philippines, through the Office of the Solicitor General, appealed this decision to the Court of Appeals (CA). The CA affirmed the RTC's order, leading to the present petition. The Petition: The Republic of the Philippines filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. The petitioner argues that the respondents failed to adequately prove that the subject property is alienable and disposable land of the public domain, a prerequisite for land registration under Presidential Decree No. 1529. Specifically, the petitioner contends that a certification from the DENR-NCR and a conversion plan are insufficient; instead, an official release of the property as alienable and disposable by the DENR Secretary is required.
Issue(s)
Whether the Court of Appeals erred in affirming the findings of the trial court that the respondents are entitled to their application for registration of title over the subject property, considering the sufficiency of the DENR-NCR's Certification, conversion plan, and technical descriptions as proof of the alienable and disposable character of the subject property.
Ruling
The petition is GRANTED. The Decision dated September 30, 2013 and Resolution dated January 29, 2014 of the Court of Appeals in CA-G.R. CV No. 95382 are REVERSED and SET ASIDE. The application for registration filed by respondents is DISMISSED.
Ratio Decidendi
On the sufficiency of proof for alienable and disposable character of the land and entitlement to registration: The Court held that the conversion plan, technical descriptions of the property, and the Certification issued by the DENR-NCR are insufficient proof of the alienable and disposable character of the subject property. The respondents failed to prove their entitlement thereto under Chapter III, Section 14 of P.D. No. 1529. This section requires applicants to establish possession under a bona fide claim of ownership since June 12, 1945, or earlier, and that the property sought to be registered was declared alienable and disposable at the time of the application. The Court reiterated its ruling in Rep. of the Phils. v. Lualhati, emphasizing that certifications issued by the CENRO, or specialists of the DENR, as well as Survey Plans prepared by the DENR containing annotations that the subject lots are alienable, do not constitute incontrovertible evidence to overcome the presumption that the property sought to be registered belongs to the inalienable public domain. Rather, the Court stressed the importance of proving alienability by presenting a copy of the original classification of the land approved by the DENR Secretary and certified as true copy by the legal custodian of the official records. The DENR-NCR's Certification dated May 22, 2009, relied upon by the respondents, was deemed misplaced. The Court found that the respondents' reliance on this certification was misplaced, as it did not meet the stringent evidentiary standard required for land registration cases concerning alienable and disposable lands of the public domain. The presumption that land of the public domain is inalienable must be overcome by the proper documentary evidence as mandated by law and jurisprudence.
Main Doctrine
A certification from the DENR, or its CENRO or specialists, or survey plans containing annotations that the subject lots are alienable, do not constitute incontrovertible evidence to overcome the presumption that the property sought to be registered belongs to the inalienable public domain. The applicant must present a copy of the original classification of the land approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records.