G.R. No. 108926 July 12, 1996
REPUBLIC OF THE PHILIPPINES, petitioner, vs. COURT OF APPEALS and HEIRS OF DEMOCRITO O. PLAZA, respondents.

FACTS

Democrito O. Plaza filed a petition for original registration of title over a 45,295-square-meter parcel of land in Las Piñas. He traced his claim of ownership through a series of purchases from the heirs of Gil Alhambra, who themselves acquired it from prior owners dating back to Santos de la Cruz in 1913. Plaza and his predecessors-in-interest presented tax declarations and payment receipts to evidence their possession. He alleged open, continuous, exclusive, and notorious possession in the concept of an owner since June 12, 1945, or earlier.
The Republic of the Philippines opposed the application, asserting that the land remained part of the public domain and that Plaza failed to prove the requisite possession. Several other private oppositors, including the Heirs of Santos de la Cruz and the Kadakilaan Estate, also claimed ownership based on different titles. During the pendency of the case, President Corazon C. Aquino issued Proclamation No. 679, reserving the area for a Slum Improvement and Resettlement (SIR) site. The Regional Trial Court nonetheless granted Plaza’s application for registration, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming the registration of the land in favor of Democrito O. Plaza despite the issuance of Proclamation No. 679 reserving the land for a public purpose.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The core legal logic rests on the principle that a presidential proclamation classifying land for a public purpose cannot defeat a vested or registrable right that has already been established in a judicial proceeding. At the time Proclamation No. 679 was issued, the controversy over the land’s ownership was already sub judice; the court had acquired jurisdiction to determine the conflicting claims. The proclamation itself contained a cautionary clause stating it was “subject to private rights, if any there be,” which explicitly acknowledged that existing vested rights must be respected.
The Court found that Plaza had sufficiently established his registrable title by presenting clear and convincing evidence of his and his predecessors-in-interest’s open, continuous, exclusive, and notorious possession of the land under a bona fide claim of ownership since June 12, 1945. This possession, coupled with the series of tax declarations and deeds of sale, substantiated a claim within the operation of the Public Land Act. Therefore, his right to the land had crystallized into an imperfect title subject to judicial confirmation, which right could not be nullified by a subsequent executive act. The proclamation’s proper effect, given the court’s confirmation of Plaza’s title, was to obligate the government, should it wish to use the land for the SIR program, to acquire it through the legal process of expropriation and payment of just compensation.