Republic v. Pasig Rizal Co.
MODIFICATIONFacts
The Antecedents: Sometime in 1958, Manuel Dee Ham had a 944-square meter parcel of land in Barangay Caniogan, Pasig City (Subject Property) surveyed. After his death in 1961, his heirs transferred their beneficial ownership over the property to their family corporation, respondent Pasig Rizal Co., Inc. (PRCI). PRCI and its predecessors-in-interest have allegedly been in possession of the property since Procedural History: In 2010, PRCI filed an application for original registration of title before the Regional Trial Court (RTC) of Pasig City, asserting ownership based on more than fifty years of open, continuous, exclusive, and notorious possession. The RTC granted the application, confirming PRCI's title. The Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed to the Court of Appeals (CA). The CA affirmed the RTC's decision, finding that the certifications from the Department of Environment and Natural Resources (DENR) were sufficient to prove that the Subject Property was alienable and disposable agricultural land since March 11, The Petition: The Republic filed a petition for review on certiorari under Rule 45 before the Supreme Court. It argued that PRCI failed to present sufficient proof of the land's alienable and disposable character according to the stringent requirements established in Republic v. T.A.N. Properties, Inc. and Republic v. Hanover. Specifically, PRCI did not present a certified true copy of the original land classification approved by the DENR Secretary and failed to present the government officers who issued the certifications to testify on their contents.
Issue(s)
Whether PRCI sufficiently proved that it is entitled to a decree of registration over the Subject Property, considering the prevailing jurisprudence, the subsequent enactment of Republic Act No. 11573, and the interplay between constitutional and civil law concepts of property, including the requirements for converting property of public dominion to patrimonial property.
Ruling
WHEREFORE, the petition for review on certiorari is DENIED in part. The February 25, 2014 Decision and June 27, 2014 Resolution of the Court of Appeals in CA-G.R. CV. No. 98531 are AFFIRMED insofar as it holds that Pasig Rizal Co., Inc., has been in open, continuous, exclusive, and notorious possession of the Subject Property since 1956. The case is REMANDED to the Court of Appeals for reception of evidence on the Subject Property's land classification status based on the parameters set forth in Section 7 of Republic Act No. 11573. Thereafter, the Court of Appeals is directed to resolve the case with due and deliberate dispatch.
Ratio Decidendi
On the sole issue: The Supreme Court ruled that while PRCI established the requisite possession, its evidence on land classification must conform to the new standards set by Republic Act No. 11573. The Court clarified the interplay between constitutional and civil law concepts of property. It held that the operative act which converts property of public dominion to patrimonial property is its classification as alienable and disposable land of the public domain, as this serves as the State's manifestation of its lack of intent to retain the same for public use. The Court clarified that the second requirement in Heirs of Mario Malabanan v. Republic—an express government manifestation that the land is no longer retained for public service—applies only to 'converted' patrimonial property under Article 422 of the Civil Code, i.e., property that had been previously utilized by the State for some public purpose. During the pendency of the case, RA 11573 took effect on September 1, 2021. The Court held that RA 11573 is a curative statute and creates new rights, thus it must be applied retroactively to pending land registration cases. Section 6 of the Act amended Section 14(1) of PD 1529, shortening the required period of possession to at least twenty (20) years immediately preceding the filing of the application. Section 7 of the Act superseded the stringent evidentiary requirements from T.A.N. Properties and Hanover, now deeming a duly signed certification by a DENR geodetic engineer on the approved survey plan as sufficient proof that the land is alienable and disposable. Applying the new law, PRCI's possession since 1956 for over 54 years clearly satisfies the new 20-year requirement. However, the DENR certifications it presented do not comply with the new parameters under Section 7 of RA 11573. In the interest of substantial justice, the Court deemed it proper to remand the case to the CA to allow PRCI to present additional evidence on the land's classification status in accordance with the new law. The Court then laid down guidelines for the bench and bar on the retroactive application of RA 11573.
Main Doctrine
The classification of public land as alienable and disposable is the operative act that converts it from property of public dominion to patrimonial property of the State, making it susceptible to private acquisition through prescription. Republic Act No. 11573, which simplifies the requirements for judicial confirmation of imperfect titles, is a curative statute that applies retroactively to all pending applications. This law shortens the required period of possession to at least twenty (20) years and simplifies the evidentiary requirement for proving land classification status, superseding the stringent standards previously set in jurisprudence like Republic v. T.A.N. Properties.