GR 147359; (March, 2008) (Digest)
G.R. No. 147359 ; March 28, 2008
IN RE: APPLICATION FOR LAND REGISTRATION OF TITLE FIELDMAN AGRICULTURAL TRADING CORPORATION, represented by KAM BIAK Y. CHAN, JR., Petitioner, vs. REPUBLIC OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Fieldman Agricultural Trading Corp. (FATCO) filed an application for original registration of title over three parcels of land in Bacnotan, La Union. FATCO claimed ownership through various deeds of conveyance from its predecessors-in-interest and asserted that it and its predecessors had been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership for over thirty years. The Republic, through the Office of the Solicitor General, filed an opposition, contending the land was part of the public domain and that FATCO failed to prove possession since June 12, 1945, as required by law. The Regional Trial Court granted FATCO’s application, but the Court of Appeals reversed this decision, prompting FATCO’s appeal to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in reversing the trial court’s grant of FATCO’s application for original registration of title.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that for lands of the public domain to be registered under Section 14(1) of Presidential Decree No. 1529, the applicant must prove: (1) that the land forms part of the disposable and alienable agricultural land of the public domain, and (2) that the applicant and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. FATCO failed to satisfy both requisites.
First, FATCO did not present a certification from the proper government agency that the subject lands were classified as alienable and disposable. The mere presentation of tax declarations and survey plans is insufficient to overcome the presumption that the land remains part of the inalienable public domain. Second, FATCO’s evidence of possession was inadequate. Tax declarations, while indicative of possession, are not conclusive evidence of ownership. The earliest tax declaration presented was from 1948, which does not establish possession prior to June 12, 1945. Furthermore, the deeds of conveyance from FATCO’s predecessors did not prove the required length and character of possession. Consequently, FATCO failed to discharge the burden of proving a registrable title over the subject properties.