GR 146527; (January, 2005) (Digest)
G.R. No. 146527 ; January 31, 2005
Republic of the Philippines, petitioner, vs. Manna Properties, Inc., Represented by its President, Jose Tanyao, respondent.
FACTS
Respondent Manna Properties, Inc. filed an application for original registration of title over two parcels of land in San Fernando, La Union. The Republic, through the Office of the Solicitor General, opposed the application, arguing that the applicant, as a private corporation, is disqualified from acquiring alienable lands of the public domain under the Constitution. The Regional Trial Court granted the application, finding that Manna Properties had substantiated its claim with clear evidence. The Court of Appeals affirmed the trial court’s decision, dismissing the Republic’s argument regarding non-compliance with jurisdictional requirements for publication and emphasizing that the 90-day period for setting the initial hearing under the Property Registration Decree is merely directory.
ISSUE
The core issue is whether Manna Properties, a private corporation, has sufficiently established its registrable title over the subject lands, particularly by proving that the lands are alienable and disposable and that it and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier.
RULING
The Supreme Court REVERSED the Court of Appeals and DENIED the application for registration. The Court held that Manna Properties failed to prove that the lands are alienable and disposable. While a certification from the Department of Environment and Natural Resources (DENR) stated the lands were alienable and disposable as of March 15, 1982, this date is insufficient. For a judicial confirmation of imperfect title, the applicant must conclusively establish that the land was already classified as alienable and disposable on or before June 12, 1945. The 1982 certification does not meet this stringent requirement. Furthermore, the evidence of possession was inadequate. The testimony of a witness regarding possession by predecessors-in-interest was deemed general and uncorroborated. The tax declarations presented were recent and sporadic, failing to demonstrate the required possession since June 12, 1945. Consequently, Manna Properties did not overcome the presumption that the land remains part of the inalienable public domain.