In Republic of the Philippines vs. Crisanto S. Raneses, the Supreme Court emphasized the necessity of providing incontrovertible evidence to prove that land being registered is alienable and disposable public land. The Court reversed the decisions of the lower courts, which had granted Crisanto S. Raneses’ application for land registration, because Raneses failed to provide sufficient proof that the land in question had been officially classified as alienable. This ruling reinforces the Regalian doctrine, which presumes that all lands not privately owned belong to the State, underscoring the burden on applicants to demonstrate that the government has positively acted to classify the land as alienable.

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The case began when Crisanto S. Raneses applied for original registration of land title for two parcels of land in Barangay Napindan, Taguig City. Raneses claimed that his parents had been in continuous possession of the properties since 1945 and that he acquired ownership through an Extrajudicial Settlement of Estate. He presented tax declarations dating back to 1980, a Conversion-Subdivision Plan indicating the land was within an alienable and disposable area according to a 1968 certification, and an Inter-Office Memorandum from the Laguna Lake Development Authority (LLDA) stating the land was above the reglementary elevation.

The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed the application, arguing that Raneses had not provided sufficient evidence to prove the land was alienable and disposable. The LLDA also filed an opposition, asserting that the land was below the prescribed elevation, making it part of Laguna Lake’s bed and thus inalienable. The Regional Trial Court (RTC) initially granted Raneses’ application, a decision later affirmed by the Court of Appeals (CA), which gave more weight to the Inter-Office Memorandum than the LLDA’s own memorandum questioning the land’s elevation.

Building on the cornerstone of Philippine property law, the Supreme Court reiterated the Regalian doctrine, enshrined in Section 2, Article XII of the 1987 Constitution. This doctrine declares that all lands of the public domain belong to the State. Therefore, any claim of private ownership must be clearly established, as all lands not appearing to be privately owned are presumed to belong to the State.

The Supreme Court cited Section 14(1) of Presidential Decree (P.D.) No. 1529, the Property Registration Decree, which outlines who may apply for land registration. This provision ties into Section 48(b) of the Public Land Act, as amended by P.D. No. 1073, detailing the requirements for citizens occupying public lands to perfect their titles. To successfully register land under these provisions, applicants must demonstrate that:

SEC. 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 representatives:

(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.

1. The land is alienable and disposable.
2. The applicant, or their predecessors, have been in open, continuous, exclusive, and notorious possession.
3. Possession has been under a bona fide claim of ownership since June 12, 1945, or earlier.

The court emphasized that the burden of proof rests on the applicant to overturn the presumption that the land is part of the inalienable public domain. This requires presenting incontrovertible evidence. The Court found Raneses’ evidence lacking because it primarily consisted of a Conversion-Subdivision Plan and an Inter-Office Memorandum from the LLDA.

Specifically, the Court pointed out that the Conversion-Subdivision Plan, with its annotation stating the land was within an alienable and disposable area based on a 1968 certification, was insufficient. Citing Republic v. Dela Paz, the Court clarified that such notations by a surveyor-geodetic engineer do not constitute incontrovertible evidence. Rather, the Court requires a certificate of land classification status issued by the Community Environment and Natural Resources Office (CENRO) or the Provincial Environment and Natural Resources Office (PENRO) of the DENR.

Moreover, the applicant must demonstrate that the DENR Secretary approved the land classification, releasing the land as alienable and disposable, and that this classification aligns with a survey verification by CENRO or PENRO. This includes presenting a copy of the original classification approved by the DENR Secretary, certified by the legal custodian of official records. These stringent requirements underscore the need for concrete, official governmental actions to prove land alienability.

The Supreme Court did not find it necessary to delve into the conflicting LLDA memoranda (the Inter-Office Memorandum versus the ECD Memorandum). This was due to Raneses’ failure to meet the fundamental requirement of proving the land’s alienability in the first place. Even if the Inter-Office Memorandum supported Raneses’ claim that the land was above the reglementary elevation, it did not address the more critical issue of whether the land had been officially classified as alienable and disposable. As stated in Republic of the Philippines v. Lydia Capco de Tensuan, when the DENR or LRA opposes registration due to inalienability, the applicant must first provide satisfactory proof of alienability before the burden shifts to the opposing party.

While we may have been lenient in some cases and accepted substantial compliance with the evidentiary requirements set forth in T.A.N. Properties, we cannot do the same for Tensuan in the case at bar.

We cannot afford to be lenient in cases where the Land Registration Authority (LRA) or the DENR oppose the application for registration on the ground that the land subject thereof is inalienable. In the present case, the DENR recognized the right of the LLDA to oppose Tensuan’s Application for Registration; and the LLDA, in its Opposition, precisely argued that the subject property is part of the Laguna Lake bed and, therefore, inalienable public land. We do not even have to evaluate the evidence presented by the LLDA given the Regalian Doctrine. Since Tensuan failed to present satisfactory proof that the subject property is alienable and disposable, the burden of evidence did not even shift to the LLDA to prove that the subject property is part of the Laguna Lake bed.

The Court concluded that Raneses had not presented the necessary documentary evidence to prove the land was alienable and disposable. Consequently, the Supreme Court reversed the lower courts’ decisions and dismissed Raneses’ application for land registration. This case serves as a crucial reminder of the stringent requirements for land registration in the Philippines, emphasizing the importance of providing concrete, official documentation to support claims of land alienability.

FAQs

What was the key issue in this case?	The key issue was whether Crisanto S. Raneses provided sufficient evidence to prove that the land he sought to register was alienable and disposable public land, a prerequisite for land registration under Philippine law.
What is the Regalian Doctrine?	The Regalian Doctrine, enshrined in the Philippine Constitution, states that all lands of the public domain belong to the State. Any claim of private ownership must be proven against this presumption.
What evidence did Raneses present to support his claim?	Raneses presented tax declarations, a Conversion-Subdivision Plan indicating the land was within an alienable area per a 1968 certification, and an Inter-Office Memorandum from the LLDA stating the land’s elevation.
Why was Raneses’ evidence deemed insufficient?	The Supreme Court found the Conversion-Subdivision Plan and LLDA memorandum insufficient as they did not constitute incontrovertible evidence of alienability. Official certifications from CENRO or PENRO and DENR approval were required but lacking.
What documents are required to prove land is alienable and disposable?	The applicant must present a certificate of land classification status issued by CENRO or PENRO, proof of DENR Secretary approval of the land classification, and a certified copy of the original classification approved by the DENR Secretary.
What is the significance of the June 12, 1945, date?	Under Section 14(1) of P.D. No. 1529, applicants must demonstrate open, continuous, exclusive, and notorious possession of alienable and disposable lands since June 12, 1945, or earlier, to qualify for land registration.
What happened to Raneses’ application for land registration?	The Supreme Court reversed the lower courts’ decisions and dismissed Raneses’ application for land registration due to insufficient proof that the land was alienable and disposable.
What is the burden of proof in land registration cases?	The applicant bears the burden of proving, by incontrovertible evidence, that the land subject of the application is alienable and disposable. This is because the land is presumed to belong to the state.

This case underscores the strict evidentiary requirements for land registration in the Philippines, particularly concerning the classification of land as alienable and disposable. Applicants must provide concrete and official documentation to substantiate their claims, reinforcing the State’s ownership under the Regalian doctrine.

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. Crisanto S. Raneses, G.R. No. 189970, June 02, 2014