G.R. No. 198629 . April 05, 2022
REPUBLIC OF THE PHILIPPINES, PETITIONER, VS. EFREN S. BUENAVENTURA, RESPONDENT.

FACTS

On January 11, 2008, respondent Efren S. Buenaventura filed a Petition before the Regional Trial Court (RTC) of San Mateo, Rizal, applying for the original registration of title of Lot No. 1788, Cad. 674. He alleged he purchased the property from Lorenzo Habagat via a Deed of Absolute Sale dated August 4, 1993, declared it for taxation under his name, occupied it exclusively, and religiously paid real property taxes. The Republic, through the Office of the Solicitor General, opposed the application. During trial, Buenaventura presented himself and witnesses from the Land Registration Authority and the DENR-CENRO, who testified that the subject property was not covered by any prior title and was within an alienable and disposable zone. The RTC granted the application. The Court of Appeals affirmed the RTC decision, ruling that the CENRO certification was sufficient to prove alienability and that Buenaventura had established his ownership and possession. The Republic filed the instant petition, arguing that a CENRO certification alone is insufficient to prove alienability and that Buenaventura failed to prove the required possession and ownership.

ISSUE

Whether the Court of Appeals erred in affirming the grant of Buenaventura’s application for original land registration despite the alleged absence of incontrovertible proof that the land is alienable and disposable and that respondent is entitled to confirmation of title.

RULING

The Supreme Court DENIED the petition in part and REMANDED the case to the Court of Appeals. The Court held that for original registration under Section 14(1) of Presidential Decree No. 1529, an applicant must prove: (1) the land is alienable and disposable land of the public domain; and (2) the applicant and 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, or earlier. Regarding alienability, the Court reiterated that the applicant must present a copy of the original classification approved by the DENR Secretary and certified as a true copy by its legal custodian, which Buenaventura failed to do as he only presented a CENRO certification. However, in light of the intervening law, Republic Act No. 11573 (which took effect on September 1, 2021), the rules on evidence for alienability and disposability have been relaxed. Section 7 of R.A. 11573 now provides that a CENRO or PENRO certification is sufficient to prove the land’s classification status. Consequently, the case was remanded to the Court of Appeals for reception of evidence on the subject property’s land classification status based on the new parameters under R.A. 11573.