G.R. No. 141325 & 141174 ; July 31, 2006
PELBEL MANUFACTURING CORPORATION, Substituted by Pelagia Beltran, and Virginia Malolos, petitioners, vs. HON. COURT OF APPEALS, and THE REPUBLIC OF THE PHILIPPINES, respondents. ALADDIN F. TRINIDAD and AQUILINA C. BONZON, petitioners, vs. REPUBLIC OF THE PHILIPPINES (LAGUNA LAKE DEVELOPMENT AUTHORITY), respondent.

FACTS

Petitioners Pelagia Beltran, Aladdin Trinidad, and Virginia Malolos applied for original registration of two parcels of land in San Juan, Taytay, Rizal. The Laguna Lake Development Authority (LLDA) filed a manifestation, asserting that based on a topographic map, the lots were below the 12.50-meter elevation and thus formed part of the Laguna Lake bed, making them inalienable lands of the public domain. The Office of the Solicitor General also filed an opposition, contending the applicants failed to prove the requisite possession since June 12, 1945.
The Regional Trial Court granted the application, adjudicating the lots to the petitioners. It found they had proven peaceful, continuous, and public possession for over thirty years. The LLDA moved to set aside the decision, reiterating its claim that the lands were part of the lake bed. The Court of Appeals reversed the RTC, holding the lands were inalienable and petitioners failed to establish registrable title. Petitioners elevated the case to the Supreme Court.

ISSUE

Whether petitioners have sufficiently established that the subject properties are alienable and disposable lands of the public domain and that they have acquired a registrable title thereto.

RULING

The Supreme Court denied the petitions and affirmed the Court of Appeals. The legal logic is anchored on two fundamental principles of land registration. First, applicants bear the burden of conclusively proving that the land is alienable and disposable. The LLDA’s evidence, showing the lots are below the 12.50-meter elevation, established a prima facie case that they form part of the Laguna Lake bed, which is public dominion. Petitioners failed to rebut this with clear and positive evidence, such as a certification from the proper government agency declaring the land alienable. The Court distinguished the cited case of Republic v. CA and Santos del Rio, as it involved seasonal flooding from rains, not permanent classification as part of a lake bed.
Second, petitioners failed to prove the requisite possession and occupation. For original registration under Section 14(1) of the Property Registration Decree, possession must be open, continuous, exclusive, and notorious since June 12, 1945, or earlier. The evidence presented, primarily tax declarations from 1980 onwards and general testimonies, was insufficient. The late declaration for taxation purposes militated against a claim of possession since 1945. The Court emphasized that the State, as the source of any asserted right to ownership, cannot be put to a proof of its title. The applicants must overcome the presumption that the land remains part of the inalienable public domain. Petitioners here did not discharge this twin burden of proof regarding alienability and possession.