Tax Declarations as Proof of Ownership in Philippine Land Registration

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G.R. No. 108926, July 12, 1996

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Imagine you’ve been diligently paying property taxes for decades, believing you rightfully own the land. But when you try to register the title, the government contests your claim, arguing you haven’t proven ownership. This scenario highlights the critical role of tax declarations and other evidence in establishing land ownership in the Philippines.

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This case, Republic of the Philippines vs. Court of Appeals and Heirs of Democrito O. Plaza, delves into the weight of tax declarations and the required period of possession for land registration. It clarifies how these factors contribute to proving ownership, even in the face of government opposition.

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Legal Principles of Land Registration in the Philippines

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Philippine land registration laws are governed primarily by Presidential Decree No. 1529, also known as the Property Registration Decree. Section 14 of this decree outlines the requirements for original registration of title, stating that individuals who have been in open, continuous, exclusive, and notorious possession and occupation of alienable and disposable lands of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier, can apply for registration.

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Key provisions from P.D. 1529 include:

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Section 14. Who may apply. The following persons may file in the proper Court of First Instance an application for registration of title to land, whether personally or through their duly authorized representative:

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(1) Those who by themselves or through their predecessors-in-interest have been in open, continuous, exclusive and notorious possession and occupation of alienable and disposable lands of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier.

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Tax declarations, while not conclusive evidence of ownership, serve as strong indicators of possession in the concept of an owner. The Supreme Court has consistently held that paying taxes on a property demonstrates a sincere belief in one’s ownership and an intention to contribute to government revenues.

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Consider this example: A family has been paying property taxes on a piece of land for over 50 years, but they do not have a formal title. Under Philippine law, their consistent tax payments can be used as evidence to support their claim of ownership when applying for land registration.

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Case Summary: Republic vs. Court of Appeals and Heirs of Plaza

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Democrito O. Plaza filed a petition to register land in Las Pinas, Metro Manila, claiming ownership through a deed of sale and long-term possession by himself and his predecessors-in-interest. The Republic of the Philippines opposed the petition, arguing that Plaza and his predecessors had not been in open, continuous, exclusive, and notorious possession since June 12, 1945, and that the land was part of the public domain.

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The case journeyed through the following stages:

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• The Regional Trial Court (RTC) of Makati confirmed Plaza’s title.

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• The Republic appealed to the Court of Appeals (CA), which affirmed the RTC’s decision.

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• The Republic then appealed to the Supreme Court.

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The Supreme Court upheld the CA’s decision, emphasizing the significance of tax declarations and the continuous payment of property taxes as evidence of ownership. The Court stated:

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Although tax declarations or realty tax payments of property are not conclusive evidence of ownership, nevertheless, they are good indicia of possession in the concept of owner for no one in his right mind would be paying taxes for a property that is not in his actual or at least constructive possession.

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The Court also noted that the government’s claim that the land was withdrawn from the alienable portion of the public domain by Presidential Proclamation No. 679 did not negate Plaza’s existing private rights. The proclamation itself was