Republic v. Banal na Pag-aaral
REITERATIONFacts
The Antecedents: Respondent Banal na Pag-aaral, Phil., Inc. filed an application for the registration of Lot Nos. 2304 and 2312, Cad. 482-D Amadeo Cadastre, consolidated as Lot No. 9404, with an area of 57,989 square meters situated in Barangay Dagatan, Amadeo, Cavite. The respondent claimed ownership and possession of the subject lot based on continuous, exclusive, and notorious possession and occupation in the concept of an owner since before World War II, originating from its predecessors-in-interest, the Heirs of Hermogenes Bayot. To support its claim, the respondent presented a DENR certification indicating the lot is alienable and disposable, and a copy of an approved survey plan noting the same. Additionally, evidence was presented to establish prior ownership and possession by Hermogenes Bayot and his heirs, including tax declarations and testimonial evidence. Procedural History: The Regional Trial Court (RTC) of Tagaytay City, Branch 18, approved the respondent's application for registration in a Decision dated April 1, 2003, finding that the respondent and its predecessors-in-interest had sufficiently established open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since prior to June 12, 1945, and that the lot was alienable and disposable. The Republic of the Philippines appealed this decision to the Court of Appeals (CA). Initially, the CA reversed the RTC's decision and dismissed the application without prejudice for failure to establish the land's alienable and disposable nature. However, upon the respondent's motion for reconsideration, which included a CENRO Certification and a copy of Forestry Administrative Order No. 4-1656, the CA issued an Amended Decision on January 8, 2010, affirming the RTC's approval. The CA subsequently denied the Republic's motion for reconsideration in a Resolution dated August 3, 2010. The Supreme Court later remanded the case to the CA for further proceedings to determine the authenticity and due execution of the CENRO Certification, which the CA subsequently found to be authentic and duly issued. The Petition: The Republic of the Philippines filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's Amended Decision and Resolution. The petitioner argued that even with the admission of the additional documents, the respondent failed to establish its registrable title, specifically questioning whether the respondent and its predecessors-in-interest had been in possession of the subject lot since June 12, 1945, or earlier, given that the earliest tax declarations only dated back to 1948. The core issues before the Supreme Court were whether the respondent had possessed the subject lot for the length of time required by law and whether it had proven a registrable title thereto.
Issue(s)
Whether respondent has possessed the subject lot for the length of time required by law. Whether respondent has proven a registrable title thereto.
Ruling
The petition is meritorious. The Court affirms the Amended Decision and Resolution of the Court of Appeals, upholding the RTC's approval of respondent Banal na Pag-aaral, Phil., Inc.'s application for original registration of its imperfect title over the subject lot.
Ratio Decidendi
On the issue of whether respondent has possessed the subject lot for the length of time required by law: The Court found that respondent adequately established possession and occupation of the subject lot of the nature and duration required by law. To support this, respondent presented the testimony of Melanio Ambat, who testified that he knew of Hermogenes' ownership of the subject lot since around 1941, before the Japanese-American war. Melanio, a barrio mate, observed Hermogenes' possession and even tilled a portion of the land. He also stated that no other person claimed ownership. The Court considered Melanio's testimony credible, noting that at 15 years old, he was capable of perceiving ownership, and his knowledge was reinforced through the years until he testified at 74. The Court also held that the earliest tax declaration in 1948 does not necessarily negate possession since June 12, 1945, or earlier, especially when supported by credible testimony and in the absence of other claimants. Tax declarations are considered good indicia of possession in the concept of an owner, and their belated issuance does not negate prior possession. On the issue of whether respondent has proven a registrable title thereto: The Court ruled that respondent sufficiently established that the subject lot is alienable and disposable land of the public domain. The applicant bears the burden of proving this classification. Respondent presented a CENRO Certification stating the lot falls within Alienable or Disposable Land under Project No. 5 per Land Classification Map No. 3013, as approved under FAO No. 4-1656. A certified copy of FAO No. 4-1656 was also presented, declaring portions of the public domain, including those in Trece Martires, as alienable and disposable. Although submitted belatedly, the petitioner did not contest their admissibility. The Court noted that the government's positive act of declaration that the lot is alienable and disposable, as evidenced by these documents, enjoys the presumption of regularity. Furthermore, the Court clarified that the land sought to be registered need not have been declared alienable and disposable since June 12, 1945, or earlier; it is sufficient that it was declared so at any time prior to the filing of the application. The Court found that respondent met this requirement, thus proving a registrable title.
Main Doctrine
To prove that land subject to an application for original registration is alienable and disposable, the applicant must present a copy of the original classification approved by the DENR Secretary and certified by the legal custodian, and a certificate of land classification status from the CENRO or PENRO stating that the land falls within the approved area. While the land need not have been declared alienable and disposable since June 12, 1945, it must be shown to be so at the time of the filing of the application. Possession and occupation must be open, continuous, exclusive, and notorious under a bona fide claim of ownership since June 12, 1945, or earlier, with tax declarations serving as good indicia of such possession.