In Republic vs. Alejandre, the Supreme Court reiterated the importance of the Regalian doctrine, emphasizing that all lands not clearly under private ownership are presumed to belong to the State. The Court ruled that applicants for land registration must provide incontrovertible evidence that the land is alienable and disposable, overturning the lower courts’ decisions. This case underscores the burden of proof on individuals claiming private land ownership and reaffirms the State’s inherent ownership of public lands.

Land Claim Under Scrutiny: When is a Deed Enough to Overcome State Ownership?

Spouses Ildefonso and Zenaida Alejandre sought to register a 256 square meter parcel of land in Bangued, Abra, claiming ownership through a deed of sale from Angustia Lizardo Taleon, who allegedly inherited it. The Republic opposed, arguing the Alejandres failed to prove open, continuous possession since June 12, 1945, and that the land remained part of the public domain. The Regional Trial Court initially granted the application, later amended to reflect a slightly larger area. The Court of Appeals affirmed, stating the Alejandres acquired ownership through a contract of sale, falling under Section 14(4) of Presidential Decree No. 1529, which pertains to those who have acquired ownership of land in any other manner provided by law. Dissatisfied, the Republic elevated the case to the Supreme Court.

The Supreme Court, in its analysis, grounded its decision on fundamental principles of land ownership in the Philippines. The Court emphasized that the basis for land ownership stems from Article 419 of the Civil Code, which distinguishes property as either of public dominion or private ownership. The classification of public dominion is further elaborated in Article 420, identifying properties intended for public use, public service, or national wealth development. Conversely, private ownership encompasses patrimonial property of the State, local government units, and property belonging to private individuals, as outlined in Articles 421, 424, and 425 of the Civil Code, respectively.

Building on this foundation, the Court invoked the Regalian doctrine, enshrined in Section 3, Article XII of the 1987 Constitution. This doctrine classifies public domain lands into agricultural, forest or timber, mineral lands, and national parks, stipulating that only agricultural lands can be declared alienable. The Supreme Court underscored the significance of this provision, explaining that the classification of land as alienable and disposable is a pivotal act that opens it to private ownership.

Once land is classified as alienable and disposable, it loses its characteristics as property of public dominion and assumes the nature of patrimonial property of the State, subject to private acquisition. The Court referenced Justice Edgardo L. Paras’s commentary, highlighting that while public agricultural lands initially serve for national wealth development, they transition to patrimonial property once available for public acquisition and subsequently become private property upon acquisition by individuals.

The Supreme Court emphasized that the subject of land registration applications under Section 14 of PD 1529 pertains to either alienable and disposable land of the public domain or private land. While Section 14(4) does not explicitly define the type of land, the Court clarified that it encompasses both alienable and disposable land of the public domain and private lands. This interpretation aligns with the fundamental principle that all lands not demonstrably of private ownership presumptively belong to the State. Therefore, lands not classified or released as alienable agricultural land remain part of the inalienable public domain.

The Supreme Court stressed that the burden of proof lies with the applicant to demonstrate, through incontrovertible evidence, that the land subject to registration is indeed alienable and disposable. The respondents, in this case, claimed ownership through tradition, contract of sale, and succession, all derivative modes of acquiring ownership. However, the Court found that they failed to provide sufficient evidence regarding the nature or classification of the land. The real property tax declarations, the Deed of Absolute Sale, and the technical descriptions were deemed insufficient to overcome the presumption that the land is inalienable land of public domain.

The Court stated:

Accordingly, public lands not shown to have been classified, reclassified or released as alienable agricultural land or alienated to a private person by the State remain part of the inalienable lands of public domain. Therefore, the onus to overturn, by incontrovertible evidence, the presumption that the land subject of an application for registration is alienable and disposable rests with the applicant.

Because the Alejandres failed to prove the land’s alienable status, the Supreme Court reversed the Court of Appeals’ decision and dismissed the application for land registration. This ruling underscores the enduring strength of the Regalian doctrine and clarifies the stringent requirements for proving private land ownership in the Philippines.

FAQs

What is the Regalian doctrine?	The Regalian doctrine asserts that all lands not appearing to be privately owned are presumed to belong to the State. This principle is enshrined in the Philippine Constitution.
What must an applicant prove to register land?	An applicant must provide incontrovertible evidence that the land is alienable and disposable, meaning it has been officially classified as suitable for private ownership. Evidence of open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945, or earlier may also be required.
What kind of evidence is sufficient to prove land is alienable?	Sufficient evidence includes official government acts such as presidential proclamations, executive orders, administrative actions, investigation reports from the Bureau of Lands, or legislative acts declaring the land alienable and disposable.
What happens if an applicant fails to prove the land is alienable?	If the applicant fails to prove that the land is alienable and disposable, the application for land registration will be denied, and the land remains part of the public domain.
Why are tax declarations and deeds of sale not always enough to prove ownership?	Tax declarations and deeds of sale are evidence of a claim of ownership, but they do not, on their own, prove that the land has been officially classified as alienable and disposable by the government.
What is the significance of the June 12, 1945, date?	June 12, 1945, is a benchmark date established by law. Applicants claiming ownership through possession must generally show that their possession, or that of their predecessors-in-interest, has been open, continuous, exclusive, and notorious since this date.
What is Presidential Decree No. 1529?	Presidential Decree No. 1529, also known as the Property Registration Decree, governs the registration of land in the Philippines and outlines the requirements for obtaining a certificate of title.
What is the difference between public dominion and patrimonial property?	Property of public dominion is intended for public use, public service, or the development of national wealth and is not subject to private appropriation. Patrimonial property is owned by the State in its private capacity and can be subject to sale or other forms of alienation.
Does this ruling affect previously registered lands?	This ruling primarily affects new applications for land registration. However, it reinforces the importance of due diligence and the need for proper documentation when claiming private land ownership.

The Republic v. Alejandre case serves as a clear reminder of the legal principles governing land ownership in the Philippines. It underscores the importance of understanding the Regalian doctrine and the burden of proof required to establish private land ownership. The Supreme Court’s decision emphasizes the necessity of providing incontrovertible evidence that the land is alienable and disposable to successfully register it under the Torrens system.

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. SPS. ILDEFONSO ALEJANDRE AND ZENAIDA FERRER ALEJANDRE, G.R. No. 217336, October 17, 2018