G.R. No. 116426; April 12, 2000
Republic of the Philippines, represented by the Director of Lands, petitioner, vs. Gerardo Sodsod, Respondent.

FACTS

The Director of Lands initiated cadastral proceedings for lands in Oas, Albay. Spouses Gerardo Sodsod and Felicidad Rellores filed an answer claiming ownership of Lot No. 10367, consisting of 52,847 square meters, by virtue of their and their predecessor-in-interest’s possession for over thirty years. The lot was uncontested during the hearings.
The evidence established that respondent Sodsod and his predecessor-in-interest had occupied and possessed the lot openly, continuously, adversely, notoriously, and exclusively since 1929. The Regional Trial Court ordered the registration and confirmation of the lot in the spouses’ names. The Court of Appeals affirmed this decision, prompting the Republic’s appeal to the Supreme Court.

ISSUE

Whether respondent and his predecessor-in-interest possessed the land for more than thirty years, sufficient to vest registrable title under the Public Land Act.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court emphasized that the issue is factual, and the factual findings of the Court of Appeals are generally conclusive and not reviewable. Examining the merits, the Court held that respondent fully complied with the requirements of Section 48(b) of Commonwealth Act No. 141.
The provision states that possession and occupation of alienable public land for at least thirty years under a bona fide claim of ownership ipso jure converts the land into private property, entitling the possessor to confirmation of title. The evidence conclusively showed actual, open, continuous, exclusive, peaceful, and notorious possession in the concept of an owner since 1929, exceeding the statutory period. Consequently, respondent had acquired private ownership of the land and was entitled to its registration under the Torrens system. The appeal was dismissed for lack of merit.