The Supreme Court ruled that for land registration applications under Section 14(1) of the Property Registration Decree, it is sufficient to prove that the land was alienable and disposable at the time of the application. The applicant must also demonstrate open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier, under a bona fide claim of ownership. However, the Court emphasized that a mere certification from the DENR-CENRO is insufficient to prove the alienable and disposable character of the land, requiring additional evidence for a successful land registration.

From Humble Beginnings to Land Ownership: Proving Possession for Title Registration

The case of Republic of the Philippines vs. Local Superior of the Institute of the Sisters of the Sacred Heart of Jesus of Ragusa revolves around the application for land registration filed by the respondent. The respondent based its application on Section 14(1) of Presidential Decree (P.D.) No. 1529, also known as the Property Registration Decree, claiming continuous possession of the land since 1940 through their predecessors-in-interest. The Republic opposed, arguing that the respondent’s possession should only be counted from the date the land was declared alienable and disposable. The trial court initially approved the application, a decision later affirmed by the Court of Appeals (CA). The central legal question is whether the period of possession prior to the declaration of alienability should be considered for land registration under Section 14(1) of P.D. No. 1529.

At the heart of the issue is the interpretation of Section 14(1) of P.D. No. 1529, which outlines the requirements for land registration based on possession. This section states that 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, may apply for registration of title. The petitioner argued that the 30-year period of possession should be reckoned only from the time the lot was declared alienable and disposable, while the respondent asserted that their possession, including that of their predecessors, commenced as far back as 1943.

The Supreme Court, in resolving the issue, emphasized the requisites for filing an application for registration of title under Section 14(1) of P.D. No. 1529. These include: (1) that the property is alienable and disposable land of the public domain; (2) that the applicants, by themselves or through their predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession and occupation; and (3) that such possession is under a bona fide claim of ownership since June 12, 1945, or earlier. Building on this principle, the Court relied on the testimony of Gonzales, a former possessor of the subject land, who stated that his grandfather had possessed the land as early as 1943, planting trees and introducing improvements.

The Court acknowledged the significance of proving possession on or before June 12, 1945. In this regard, the testimony of witnesses, such as Gonzales, plays a vital role. The fact that the earliest tax declaration was dated 1948 was not seen as a hindrance, as the Court referenced Republic of the Philippines v. Court of Appeals, which held that the belated declaration of the lot for tax purposes does not necessarily mean that possession did not commence earlier. The court can grant the petition for registration as long as the testimony supporting possession for the required period is credible. Moreover, the trial court took judicial notice that tax declarations kept intact in the Municipal Assessor’s Office of Silang started only in 1948. By tacking the possession of its predecessors-in-interest, the respondent fulfilled the requirement of possession in the concept of an owner prior to 1945.

Addressing the issue of when the land must be alienable and disposable, the Court cited the Naguit case, stating that “the more reasonable interpretation of Section 14(1) is that it merely requires the property sought to be registered as already alienable and disposable at the time the application for registration of title is filed.” This interpretation clarifies that the land must be classified as alienable and disposable at the time of the application, but it does not negate the requirement of proving possession since June 12, 1945, or earlier. This approach contrasts with Section 14(2), which explicitly refers to the principles on prescription under existing laws.

However, the Court also pointed out a deficiency in the evidence presented by the respondent. While the respondent submitted a certification from the DENR-CENRO stating that the land is within the alienable and disposable land, the Court, citing Republic of the Philippines v. T.A.N. Properties, Inc., emphasized that this certification alone is insufficient. The applicant must prove that the DENR Secretary had approved the land classification and released the land of the public domain as alienable and disposable. The applicant must also present a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records.

Considering the lack of sufficient evidence to prove the alienable and disposable character of the land, the Court found it necessary to remand the case to the trial court for further reception of evidence. This decision aligns with the ruling in Republic v. Bantigue Point Development Corporation, where a similar remand was ordered to allow the respondent to submit a certified true copy of the original classification approved by the DENR Secretary. Ultimately, the Court held that the respondent must be able to demonstrate the alienable and disposable character of the land in accordance with the requirements set forth in T.A.N. Properties, only then would the application for registration be granted.

FAQs

What is the key legal issue in this case?	The key issue is whether the period of possession prior to the declaration of alienability should be considered for land registration under Section 14(1) of P.D. No. 1529.
What are the requirements for land registration under Section 14(1) of P.D. No. 1529?	The requirements include: (1) the property is alienable and disposable land of the public domain; (2) applicants have been in open, continuous, exclusive, and notorious possession; and (3) possession is under a bona fide claim of ownership since June 12, 1945, or earlier.
Does the land need to be alienable and disposable since June 12, 1945?	No, the Supreme Court clarified that the land must be alienable and disposable at the time of the application for registration, not necessarily since June 12, 1945.
Is a DENR-CENRO certification sufficient to prove that the land is alienable and disposable?	No, a DENR-CENRO certification alone is not sufficient. The applicant must also prove that the DENR Secretary approved the land classification and present a certified true copy of the original classification.
What is the significance of proving possession since June 12, 1945?	Proving possession since June 12, 1945, or earlier, is crucial to demonstrate a long-standing claim of ownership and fulfill one of the requirements for land registration under Section 14(1).
What type of evidence can be used to prove possession since June 12, 1945?	Evidence can include testimonies of witnesses, tax declarations, and proof of improvements made on the land, establishing open, continuous, exclusive, and notorious possession.
What did the Supreme Court order in this case?	The Supreme Court remanded the case to the trial court for further reception of evidence to prove that the property sought to be registered is alienable and disposable land of the public domain.
What is the implication of this ruling for land registration applicants?	Applicants must ensure they have sufficient evidence to prove the alienable and disposable character of the land, including certifications and approvals from the DENR Secretary.

In conclusion, the Supreme Court’s decision in this case clarifies the requirements for land registration under Section 14(1) of P.D. No. 1529, emphasizing the need to prove both possession since June 12, 1945, and the alienable and disposable character of the land at the time of application. The ruling serves as a reminder for land registration applicants to gather sufficient evidence to support their claims and comply with the requirements set forth by law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Republic of the Philippines vs. Local Superior of the Institute of the Sisters of the Sacred Heart of Jesus of Ragusa, G.R. No. 185603, February 10, 2016