GR 134308; (December, 2000) (Digest)
G.R. No. 134308 ; December 14, 2000
SUSANA MENGUITO, EMELITA MENGUITO-MANALILI, HELEN MARTA MENGUITO-LUNA, RENATO MENGUITO, BERSAMIN MENGUITO, FROILAN MENGUITO and GENEROSO MENGUITO, petitioners, vs. REPUBLIC OF THE PHILIPPINES, respondent.
FACTS
Petitioners, successors-in-interest of the spouses Cirilo Menguito and Juana Manalo-Menguito, filed an application for registration of title over eleven parcels of land in Barrio Ususan, Taguig, Metro Manila. They claimed ownership by inheritance and asserted that they and their predecessors-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the land in the concept of an owner for more than thirty years. The Regional Trial Court of Pasig granted their application for registration.
The Republic of the Philippines appealed to the Court of Appeals. The appellate court reversed the RTC decision and dismissed the application for registration. The CA found that petitioners failed to prove two critical requisites: first, that the subject land was classified as alienable and disposable public land, and second, that they had possessed the land for the required period under a bona fide claim of ownership. Petitioners then elevated the case to the Supreme Court via a Petition for Review.
ISSUE
Whether petitioners have sufficiently established their right to have the subject land registered under their names, pursuant to the requirements for confirmation of imperfect title.
RULING
The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals. The legal logic is anchored on the fundamental principle that all lands of the public domain belong to the State, and unless proven to be alienable and disposable, they remain part of the inalienable public domain. For a successful registration under Section 48(b) of the Public Land Act, as amended by Presidential Decree No. 1073, an applicant must conclusively prove: (1) that the land is alienable and disposable public land, and (2) that they, or their predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945.
The Court held that petitioners failed to discharge this twin burden. They did not present a certification from the proper government agency attesting that the land was classified as alienable and disposable. Mere tax declarations and payments are not conclusive evidence of ownership or of the land’s alienable status. Furthermore, the evidence of possession was insufficient. The testimony of their witness, Susana Menguito, regarding possession since 1935 was deemed general and uncorroborated. The Court found no competent evidence to establish the specific, continuous, and exclusive nature of their possession for the entire statutory period required by law. Consequently, absent incontrovertible proof of both the land’s alienable status and the requisite possession, the application for registration must fail.