The Supreme Court ruled that Rovency Realty and Development Corporation (RRDC) failed to sufficiently prove its ownership claim over a large parcel of land because it did not establish open, continuous, exclusive, and notorious possession since June 12, 1945, nor did it provide sufficient evidence the land was converted to private land. This means RRDC’s application for original registration of the land was denied, reinforcing stringent requirements for land ownership claims, particularly for corporations seeking to register large tracts of land.

From Public Domain to Private Claim: Did Possession Really Equal Ownership?

This case, Republic of the Philippines v. Rovency Realty and Development Corporation, revolves around RRDC’s application for original registration of title to a 318,345 square meter (approximately 31.8 hectares) parcel of land in Cagayan de Oro City. RRDC claimed ownership based on a deed of absolute sale and argued that it and its predecessors-in-interest had been in open, continuous, adverse, and peaceful possession of the land since time immemorial. However, the Republic opposed the application, asserting that RRDC failed to prove the required possession and that the land, exceeding twelve hectares, was beyond the allowable limit for private acquisition under the Constitution.

The lower courts initially granted RRDC’s application, but the Supreme Court reversed these decisions, emphasizing the stringent requirements for proving land ownership, especially concerning alienable and disposable lands of the public domain. The Court scrutinized whether RRDC had met the criteria set forth in Presidential Decree (P.D.) No. 1529, also known as the Property Registration Decree, specifically Sections 14(1) and 14(2), which outline the conditions for original registration based on possession and prescription, respectively.

The Supreme Court addressed the contention regarding the constitutional limit on land acquisition. Section 3, Article XII of the 1987 Constitution states:

SECTION 3. Lands of the public domain are classified into agricultural, forest or timber, mineral lands, and national parks. Agricultural lands of the public domain may be further classified by law according to the uses to which they may be devoted. Alienable lands of the public domain shall be limited to agricultural lands. Private corporations or associations may not hold such alienable lands of the public domain except by lease, for a period not exceeding twenty-five years, renewable for not more than twenty-five years, and not to exceed one thousand hectares in area. Citizens of the Philippines may lease not more than five hundred hectares, or acquire not more than twelve hectares thereof by purchase, homestead, or grant.

The Court clarified that the constitutional limit primarily applies to lands of the public domain and does not restrict the acquisition of private lands. Building on this principle, the critical question became whether the subject land had already transitioned from public to private ownership due to the nature and duration of possession by RRDC’s predecessors-in-interest.

The Court emphasized the necessity of complying with either Section 14(1) or Section 14(2) of P.D. No. 1529. These sections provide distinct pathways for land registration, with Section 14(1) focusing on possession and Section 14(2) on prescription. The distinction is pivotal, as it determines the type and extent of evidence required to substantiate the ownership claim. Section 14(1) of P.D. No. 1529 stipulates 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.

To qualify under Section 14(1), applicants must prove that the land is alienable and disposable, that they and their predecessors have possessed it openly, continuously, exclusively, and notoriously, and that this possession has been under a bona fide claim of ownership since June 12, 1945, or earlier. The Court found that RRDC failed to meet these requirements, particularly because it did not present a certified true copy of the original classification approved by the DENR Secretary declaring the subject land alienable and disposable. The CENRO certification alone was deemed insufficient.

The significance of demonstrating specific acts of ownership cannot be overstated. Applicants must present concrete evidence substantiating their claim of open, continuous, exclusive, and notorious possession. General statements and legal conclusions are insufficient. The Supreme Court found that RRDC did not provide adequate evidence of dominion exercised by its predecessors-in-interest before June 12, 1945. Tax declarations dating back only to 1948 were also insufficient to establish the required period of possession and occupation.

Furthermore, the Court addressed the possibility of registration under Section 14(2) of P.D. No. 1529, which pertains to acquiring ownership of private lands by prescription. This provision requires compliance with the Civil Code, which allows the acquisition of patrimonial property of the State through prescription. However, even if land is declared alienable and disposable, it does not automatically become susceptible to acquisition by prescription. The state must also expressly declare that the property is no longer intended for public service or national development, converting it into patrimonial property.

The Court then cited the case of Heirs of Mario Malabanan vs. Republic (Malabanan), elucidating that under the Civil Code, prescription is a recognized mode of acquiring ownership of patrimonial property. However, public domain lands become patrimonial only with a declaration that these are alienable or disposable. Building on this, the Court underscored that there must also be an express government manifestation that the property is already patrimonial or no longer retained for public service or the development of national wealth, under Article 422 of the Civil Code.

Here’s the applicable provision in Article 422 of the Civil Code:

Property of public dominion, when no longer intended for public use or for public service, shall form part of the patrimonial property of the State.

In the case at hand, RRDC failed to provide evidence that the subject land had been expressly declared as no longer intended for public service or the development of national wealth. Consequently, the Court concluded that RRDC did not prove that acquisitive prescription had begun to run against the State, and thus, it could not claim title by virtue thereof. In summary, RRDC failed to meet the requisites for land registration under either Section 14(1) or Section 14(2) of P.D. No. 1529, leading to the denial of its application.

FAQs

What was the key issue in this case?	The central issue was whether Rovency Realty and Development Corporation (RRDC) sufficiently proved its claim of ownership and possession over a parcel of land to warrant original registration of title. The Supreme Court focused on compliance with the requirements of P.D. No. 1529, specifically Sections 14(1) and 14(2).
What is Section 14(1) of P.D. No. 1529?	Section 14(1) of the Property Registration Decree pertains to those 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. Applicants must prove that the land is alienable and disposable.
What is Section 14(2) of P.D. No. 1529?	Section 14(2) refers to those who have acquired ownership of private lands by prescription under existing laws, primarily the Civil Code. This requires demonstrating that the property has been declared patrimonial and that the prescriptive period has been met.
What evidence did RRDC present to support its claim?	RRDC presented deeds of absolute sale, tax declarations, and a certification from the CENRO stating that the land was alienable and disposable. However, the Supreme Court found this evidence insufficient to meet the stringent requirements for land registration.
Why was the CENRO certification not enough?	The Court ruled that the CENRO certification was not enough to prove that the land sought to be registered is alienable and disposable. RRDC needed to also present a certified true copy of the original classification approved by the DENR Secretary.
What does ‘open, continuous, exclusive, and notorious possession’ mean?	‘Open’ means the possession is visible and apparent, ‘continuous’ means uninterrupted, ‘exclusive’ means the possessor has exclusive dominion, and ‘notorious’ means the possession is generally known in the community. These elements must be proven with specific acts of ownership.
What is the significance of June 12, 1945, in land registration cases?	June 12, 1945, is the cut-off date for possession under Section 14(1) of P.D. No. 1529. Applicants must demonstrate that they and their predecessors-in-interest have been in possession of the land since this date, or earlier, to qualify for registration under this provision.
Can corporations acquire agricultural lands of the public domain?	The 1987 Constitution generally prohibits private corporations from acquiring agricultural lands of the public domain, except through lease. However, if a corporation can prove that the land was already private land at the time of acquisition, the constitutional prohibition does not apply.

This case underscores the importance of meticulously documenting and substantiating land ownership claims, especially when involving large tracts of land and corporate entities. The burden of proof rests heavily on the applicant to demonstrate compliance with all legal requirements for land registration. Strict adherence to procedural and evidentiary rules is crucial for a successful land registration application.

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. ROVENCY REALTY AND DEVELOPMENT CORPORATION, G.R. No. 190817, January 10, 2018