G.R. No. 232778 , August 23, 2023
Republic of the Philippines, Petitioner, vs. Spouses Rolly D. Tan and Grace Tan, Respondents.

FACTS

Spouses Rolly D. and Grace Tan filed an application for confirmation and registration of title over a 208-square meter parcel of land (Lot No. 9192-A) in Batangas City. They claimed acquisition of the property from the heirs of Simeon Garcia and Cirilo Garcia through extrajudicial settlements with sale executed in 2003 and 2004. They presented tax declarations dating back to 1968 in the name of spouses Simeon Garcia and Adela Marasigan, and receipts for real property tax payments. A neighbor, Felicidad Lumanglas, testified that the Garcia family had resided on the property since before 1946, though her testimony revealed inconsistencies regarding her personal knowledge from that early period. The Community Environment and Natural Resources Office (CENRO) issued a Certification and Report stating the land was within an alienable and disposable zone based on Land Classification Map No. 718 certified on March 26, 1928. The Municipal Trial Court in Cities (MTCC) granted the application. The Republic appealed, arguing the respondents failed to prove the land’s alienable and disposable status and their possession since June 12, 1945. The Court of Appeals denied the appeal. The Republic then elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the MTCC’s decision to grant the application for registration of title.

RULING

The Supreme Court GRANTED the petition, REVERSED the Court of Appeals’ Decision and Resolution, and DISMISSED the application for registration of title. The Court held that the respondents failed to prove the requisite possession and occupation since June 12, 1945, or earlier, as required for judicial confirmation of imperfect title under Section 14(1) of the Property Registration Decree. The earliest tax declaration presented was only from 1968. The testimony of the neighbor, Felicidad Lumanglas, was deemed insufficient and unreliable to establish possession since 1945, as she admitted she was not yet conscious of such matters at four years old in 1945. Furthermore, the Court ruled that the CENRO Certification, which stated the land was alienable and disposable based on a 1928 land classification map, was insufficient to prove the land’s status as of June 12, 1945. The certification did not specifically state that the land was already classified as alienable and disposable on that critical date. The applicant bears the burden of proving that the land was already classified as alienable and disposable agricultural land of the public domain on or before June 12, 1945. The respondents failed to discharge this burden. Consequently, they did not acquire an imperfect title susceptible to judicial confirmation.