G.R. No. 198585 ; July 2, 2012
Republic of the Philippines, Petitioner, vs. Metro Index Realty and Development Corporation, Respondent.

FACTS

Metro Index Realty and Development Corporation filed an application for judicial confirmation of title over three parcels of land in Indang, Cavite. The respondent claimed ownership through purchase from the Sicap siblings, who allegedly inherited the properties from their parents. To substantiate its claim, the respondent presented testimonies and evidence, including tax declarations dating back to 1956 in the names of its predecessors-in-interest, a DENR certification that the lands were alienable and disposable, and affidavits from adjoining owners. The witnesses testified that the properties had been cultivated with crops like coconut, banana, and palay, and that taxes had been religiously paid.
The Regional Trial Court granted the application, finding the respondent’s and its predecessors’ possession to be open, continuous, notorious, and adverse. The Court of Appeals affirmed this decision, ruling that the long-term tax payments and cultivation, even if limited, sufficiently proved possession in the concept of an owner. The CA emphasized that possession does not require physical presence on every square meter and that constructive possession of the entire tract can be inferred from acts on a portion.

ISSUE

Whether the respondent successfully proved that it and its predecessors-in-interest possessed the subject lands in the manner and for the period required by law to warrant judicial confirmation of imperfect title.

RULING

The Supreme Court granted the petition and reversed the Court of Appeals, denying the application for registration. The legal logic centered on the insufficiency of evidence to establish the requisite possession and occupation under Presidential Decree No. 1529. The Court clarified that for registration under Section 14(1), possession and occupation must be since June 12, 1945, or earlier. The earliest tax declaration presented was only from 1956, which failed to prove possession ante-dating the required period. The respondent could not avail of Section 14(2) on prescription either, as there was no proof that the alienable lands had been declared patrimonial property of the State at least thirty years prior to the application.
Crucially, the Court held that the evidence of possession was inadequate. Tax declarations, while indicative of a claim of title, are not conclusive evidence of ownership or of the specific character of possession required by law. The alleged cultivation—planting some coconut and fruit trees—was deemed sporadic and insufficient to constitute the open, continuous, exclusive, and notorious possession that would justify a presumptive grant from the state. Mere casual cultivation, without clear, specific, and attributable acts of dominion spanning the requisite period, does not equate to the well-nigh incontrovertible evidence demanded for land registration. The respondent failed to discharge its burden of proving a registrable title by clear and convincing evidence.