G.R. No. 112567 February 7, 2000
THE DIRECTOR, LANDS MANAGEMENT BUREAU, petitioner, vs. COURT OF APPEALS and AQUILINO L. CARIÑO, respondents.

FACTS

On May 15, 1975, private respondent Aquilino Cariño filed a petition for registration of Lot No. 6, a sugar land in Cabuyao, Laguna, with an area of 43,614 square meters. He claimed ownership through inheritance from his mother, Teresa Lauchangco, who died in 1911. He asserted that after his father’s death in 1934, he administered the property for his siblings. In 1949, through an extra-judicial partition, he and his brother Severino became co-owners, and by a 1963 deed, sole ownership was adjudicated to him. The Land Investigator’s report indicated the land was agricultural, outside any reservation, and free from conflict, with Cariño in possession.
The Regional Trial Court granted the petition for registration in 1990, a decision affirmed by the Court of Appeals in 1993. The Director of the Lands Management Bureau (now the Land Management Bureau) appealed, contending that Cariño failed to present sufficient proof of a fee simple title or of the requisite possession to justify confirmation of an imperfect title, and that he did not overcome the presumption that the land belongs to the public domain.

ISSUE

Whether the Court of Appeals erred in affirming the registration of the land in favor of Aquilino Cariño despite his alleged failure to prove ownership or the requisite possession for confirmation of an imperfect title under applicable laws.

RULING

The Supreme Court GRANTED the petition, REVERSED the Court of Appeals, and declared Lot No. 6 public land. The legal logic is twofold. First, the petition was filed under the Land Registration Act ( Act No. 496 ), which requires the presentation of specific muniments of title from the Spanish period, such as a titulo real or royal grant. Cariño failed to produce any such documentary title, warranting the dismissal of his application under this law.
Second, even if treated as an application for confirmation of imperfect title under the Public Land Act ( Commonwealth Act No. 141 ), as amended, the petition still failed. The law applicable at the time of filing in 1975 required open, continuous, exclusive, and notorious possession and occupation of agricultural lands of the public domain under a bona fide claim of ownership for at least thirty (30) years immediately preceding the application. The Court found Cariño’s evidence insufficient to prove such possession en concepto de dueño (in the concept of an owner). His testimony and tax declarations were deemed inadequate to establish the character and duration of possession required by law. Consequently, he did not overcome the presumption under the Regalian doctrine that all lands belong to the State unless alienated according to law. The land thus remains part of the public domain under the administration of the Lands Management Bureau.