Republic v. Manahan
CLARIFICATIONFacts
The Antecedents: In 2004, respondent Eduardo Manahan (Eduardo) filed an Application for original land registration with the Municipal Trial Court (MTC) over three parcels of land in San Mateo, Rizal, identified as Lot No. 320 (2,506 sq.m.), Lot No. 4500 (2,620 sq.m.), and Lot No. 4526 (2,890 sq.m.). Eduardo claimed ownership through succession from Mariano Manahan (Mariano), then through Filomena Manahan, and finally through Lourdes Manahan who sold the lots to him in 2002 via a Deed of Absolute Sale. To prove prior possession, Eduardo presented tax declarations dating back to 1948 in Mariano's name and testified that he had accompanied Filomena in supervising crop planting on the lots since he was 10 years old, yielding around six sacks of rice per harvest. Marilyn delos Angeles Diestro (Diestro), an adjacent landowner, corroborated the Manahans' ownership and cultivation of the subject lots as rice fields since time immemorial. Procedural History: The MTC granted Eduardo's application, finding that he sufficiently proved all elements of a valid title under Section 14, paragraph 1 of Presidential Decree No. 1529 (Property Registration Decree), including his qualification as a Filipino citizen, possession since 1949, and the lots' classification as alienable and disposable since March 11, 1927, per Land Classification Map No. 639, as stated in the Community Environment and Natural Resources Office (CENRO) Certification. The Republic, through the Office of the Solicitor General (OSG), appealed to the Court of Appeals (CA). The CA affirmed the MTC Decision in toto, agreeing that Eduardo sufficiently proved both the alienable and disposable status via the CENRO Certification, which enjoys the presumption of regularity, and possession since June 12, 1945, or earlier, based on the testimonial and documentary evidence. The Petition: The OSG filed a Petition for Review on Certiorari before the Supreme Court, asserting that Eduardo failed to prove a positive act from the government declassifying the subject lots from the public domain and converting them to alienable and disposable lands. The OSG argued that the CENRO Certification alone was insufficient proof, citing Republic v. TA.N. Properties, Inc., which required a certified true copy of the original land classification approved by the Department of Environment and Natural Resources (DENR) Secretary. The OSG further contended that Eduardo failed to prove possession since June 12, 1945, or earlier, as the earliest tax declarations were from 1948, and Diestro's testimony lacked specific dates of acquisition or acts of ownership by the Manahans.
Issue(s)
Whether the Court of Appeals erred in holding that Eduardo Manahan was able to adequately prove that he and his predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the subject lots under a bona fide claim of ownership for at least twenty (20) years immediately preceding the filing of the application for confirmation of title, as required by Section 14, paragraph 1 of Presidential Decree No. 1529, as amended by Section 6 of Republic Act No. 11573. Whether the Court of Appeals erred in holding that Eduardo Manahan was able to adequately prove that the subject lots have been declared alienable and disposable at the time of the filing of the Application with the MTC, in accordance with Section 14, paragraph 1 of Presidential Decree No. 1529, as amended by Section 6 of Republic Act No. 11573.
Ruling
The Petition for Review on Certiorari filed by the Republic of the Philippines is DENIED in part. The Decision dated March 2, 2020, and the Resolution dated December 10, 2020, respectively rendered by the First Division and Former First Division of the Court of Appeals (CA) in CA-G.R. CV No. 102713 are AFFIRMED insofar as they held that Eduardo Manahan, by himself and through his predecessors-in-interest, has been in open, continuous, exclusive, and notorious possession and occupation of the subject lots under a bona fide claim of ownership since 1948. The case is REMANDED to the Court of Appeals for reception of evidence on the subject lots' land classification status based on the parameters set forth in Section 7 of Republic Act No. 11573 and its implementing rules and regulations. Thereafter, the Court of Appeals is DIRECTED to resolve the present case in accordance with this Decision with due and deliberate dispatch.
Ratio Decidendi
On Issue 1: The Court found that Eduardo Manahan and his predecessors-in-interest, the Manahans, had been in open, continuous, exclusive, and notorious possession and occupation of the subject lots under a bona fide claim of ownership for at least twenty (20) years immediately preceding the filing of the application, as required by Section 14, paragraph 1 of Presidential Decree No. 1529 (Property Registration Decree), as amended by Section 6 of Republic Act No. 11573 (An Act Improving the Confirmation Process for Imperfect Land Titles). The Court applied Republic Act No. 11573 retroactively, as held in Republic v. Pasig Rizal Co., Inc., noting its curative nature which shortened the required period of possession from June 12, 1945, or earlier, to 20 years prior to the application. Evidence included tax declarations dating back to 1948 in Mariano Manahan's name, which are strong indicia of possession in the concept of an owner, as repeatedly held by the Court. Eduardo's testimony about supervising crop planting with Filomena since he was 10 years old, producing six sacks of rice per harvest, corroborated by Marilyn delos Angeles Diestro, further established actual, continuous cultivation and acts of dominion. The Court concluded that the Manahans' occupation was open, continuous, exclusive, and notorious, satisfying the possession requirement under the amended law. On Issue 2: The Court found that the land classification status of the subject lots was not sufficiently established. Prior to the effectivity of Republic Act No. 11573, a Community Environment and Natural Resources Office (CENRO) or Provincial Environment and Natural Resources Office (PENRO) certification as regards land classification, without more, was insufficient to prove alienable and disposable status, requiring also a certified true copy of the original land classification approved by the Department of Environment and Natural Resources (DENR) Secretary, which Eduardo failed to provide. Furthermore, the CENRO Certification was not properly authenticated as the issuing official was not presented to testify, rendering its contents hearsay, as established in Republic v. Hanover Worldwide Trading Corp. Even with the retroactive application of Section 7 of Republic Act No. 11573 and its Implementing Rules and Regulations (IRR), which simplified the proof, Eduardo's Advance Plan only contained a notation, not a sworn certification, by the geodetic engineer, and lacked a certification from the Chief of the Surveys and Mapping Division of the DENR Regional Office. The Court reiterated that a surveyor has no authority to reclassify lands, and mere inclusion in a cadastral survey does not prove alienable and disposable status. Due to the curative purpose of Republic Act No. 11573 and Eduardo's proven possession, the Court deemed it proper to remand the case to the Court of Appeals for the reception of evidence on the land classification status under the new parameters, citing Republic v. Buenaventura.
Main Doctrine
This case clarifies the application of Section 14, paragraph 1 of Presidential Decree No. 1529 (Property Registration Decree), as amended by Section 6 of Republic Act No. 11573 (An Act Improving the Confirmation Process for Imperfect Land Titles), regarding judicial confirmation of imperfect titles. It reiterates that Republic Act No. 11573, being a curative law, applies retroactively to pending applications, shortening the required period of possession to at least twenty (20) years immediately preceding the filing of the application. Crucially, it also details the specific evidentiary requirements under Section 7 of Republic Act No. 11573 and its Implementing Rules and Regulations (IRR) to prove that a land is alienable and disposable, emphasizing the need for proper authentication of certifications and the specific content required for such certifications.