G.R. No. 127060 . November 19, 2002.
REPUBLIC OF THE PHILIPPINES, petitioner, vs. COURT OF APPEALS, FLORENTINO CENIZA, SANTIAGO CENIZA, ESTANISLAO CENIZA, ROMEO SIMBAJON, PABLO RAMOS, ATILANO BONGO, EDGAR ADOLFO, EMMA ADOLFO, JERRY ADOLFO, GLENN ADOLFO, GINA ADOLFO, LORNA ADOLFO, CHONA ADOLFO, EVELYN ADOLFO, in her own behalf and as guardian of the minors HUBERT and AMIEL ADOLFO, and ELNITA ADOLFO in her own behalf and as guardian of minors DAVID and PRESTINE MAY ADOLFO, respondents.

FACTS

Apolinar Ceniza was the declared owner of Lot No. 1104 in Cabancalan, Mandaue City, under a 1948 tax declaration. Upon his death, his heirs partitioned the property in 1960. Through subsequent purchases and successional transfers, the private respondents acquired respective portions of the lot. On November 4, 1986, private respondents applied for registration of their titles over these portions with the Regional Trial Court (RTC) of Mandaue City. The Republic of the Philippines, through the Office of the Solicitor General, opposed the application on grounds that: (1) neither the applicants nor their predecessors-in-interest had been in open, continuous, exclusive, and notorious possession since June 12, 1945; (2) their documents did not constitute sufficient evidence of bona fide acquisition or possession; (3) any claim based on a Spanish title was barred for failure to file within the period under P.D. No. 892; and (4) the land remained part of the public domain. The RTC granted the application, finding that the applicants’ possession for over thirty years was continuous, peaceful, adverse, public, and exclusive, thereby constituting ownership. The Court of Appeals affirmed the RTC decision, holding that the property had been converted to private land through the applicants’ open, continuous, exclusive, and notorious possession for more than thirty years, satisfying the requirement under the Public Land Act. The Court of Appeals emphasized that the land had ceased to be part of the public domain and that the Republic failed to prove the land was not alienable and disposable, especially since the Bureau of Forest Development did not comply with a court order to report on the land’s status.

ISSUE

Whether the Court of Appeals erred in affirming the RTC decision granting the application for registration of title, despite the Republic’s contention that the land remains part of the inalienable public domain and that the applicants failed to prove possession since June 12, 1945, as required by law.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that under Section 48(b) of the Public Land Act, as amended by P.D. No. 1073, a citizen of the Philippines may apply for registration of alienable and disposable lands of the public domain if they, or their predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945. However, the Court reiterated the doctrine from Director of Lands v. Intermediate Appellate Court that alienable public land held by a possessor, personally or through predecessors-in-interest, openly, continuously, and exclusively for the prescribed statutory period (30 years under the Public Land Act) is converted to private property by the mere lapse of that period, ipso jure. The Court found that the private respondents and their predecessors had been in possession of the land since at least 1927—well over 30 years—as established by testimonial and documentary evidence, including tax declarations and receipts. This possession transformed the land into private property, removing it from the public domain. The Court further noted that the Republic failed to present evidence contradicting the alienable and disposable character of the land, despite an order for the Bureau of Forest Development to submit a report. The presumption of regularity in the performance of official duty meant that the tax declarations indicating agricultural use were prima facie evidence of the land’s alienable status. Thus, the applicants were entitled to confirmation of their imperfect titles.