G.R. No. L-70594 October 10, 1986
REPUBLIC OF THE PHILIPPINES, petitioner, vs. THE HON. INTERMEDIATE APPELLATE COURT and FELICIANA RODRIGUEZ, respondents.

FACTS

Private respondent Feliciana Rodriguez applied for the registration of four parcels of land in Batangas. The evidence established that the lands originally belonged to her parents, Fortunato Rodriguez and Rosa Verganza, who had been in possession since 1929. Upon their death, the lands became part of an estate settlement in a civil case, culminating in a 1954 compromise agreement and court decision allocating the subject parcels to Feliciana. She thereafter possessed the lands openly, continuously, and in the concept of an owner, cultivating them with sugar cane, palay, and corn, and declaring them for taxation purposes. The Republic, through the Director of Lands, opposed the application, arguing that the lands were not sufficiently identified and that the possession did not meet the legal requirements for acquisitive prescription.
The Court of First Instance of Batangas granted the application for registration, a decision affirmed by the Intermediate Appellate Court. The Republic elevated the case via certiorari, contending that the lower courts erred in confirming title based on mere blueprint copies of survey plans and in finding that the possession was of the nature and duration required by law.

ISSUE

Whether the Intermediate Appellate Court erred in affirming the registration of the lands in favor of Feliciana Rodriguez, specifically regarding the sufficiency of the identification of the properties and the nature and length of her possession.

RULING

The Supreme Court affirmed the decision of the Intermediate Appellate Court. On the issue of identification, the Court distinguished the cited case of Director of Lands v. Reyes. In that case, the lands were vast, uncultivated tracts within a military reservation, and the survey plans presented were either not formally offered or lacked proper approval. Here, the original tracing cloth plan was attached to the application and available to the court. The lands were covered by public land surveys bearing the approval of the Director of Lands, and the testimonies of witnesses corroborated the areas, locations, and boundaries. The lower court’s finding that the evidence sufficiently identified the lands was thus upheld.
On the issue of possession, the Court found the Republic’s contention untenable. The evidence demonstrated that Feliciana and her predecessors had been in open, exclusive, and continuous possession since 1925, exercising acts of dominion such as cultivation, enjoyment of fruits, and payment of taxes. While tax declarations alone are not proof of ownership, when coupled with actual possession, they constitute strong evidence of a claim of ownership. The possession, tacked from her parents, far exceeded the statutory period required under the Public Land Act. The Supreme Court emphasized that the factual findings of the Intermediate Appellate Court are conclusive and binding, absent any showing that they fall under established exceptions, which were not present in this case.