G.R. No. 157466 ; June 21, 2007
Republic of the Philippines, Petitioner, vs. Cheryl B. Bibonia and Joselito G. Manahan, Respondents.

FACTS

Respondents Cheryl B. Bibonia and Joselito G. Manahan (substituted for Ricardo L. Fernandez) filed an application for original registration of title over two parcels of land in Vinzons, Camarines Norte. They traced their ownership through various deeds of sale and donation from predecessors-in-interest, claiming open, continuous, exclusive, and notorious possession in the concept of owners. The Regional Trial Court granted their application, a decision affirmed in toto by the Court of Appeals.
The Republic of the Philippines appealed, contending that the respondents failed to prove the requisite possession since June 12, 1945. The Republic emphasized a Certification from the Community Environment and Natural Resources Office (CENRO) stating the subject lands were declared alienable and disposable only on January 17, 1986. Thus, at the time of the application’s filing in 1994, the property had been alienable for only eight years, making it impossible for respondents or their predecessors to have possessed it under a bona fide claim of ownership since 1945.

ISSUE

Whether respondents have sufficiently established their registrable title by proving that the lands are alienable and disposable and that they have been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945.

RULING

The Supreme Court REVERSED the decisions of the lower courts and DENIED the application for registration. The Court clarified the interpretation of Section 14(1) of Presidential Decree No. 1529. The first requisite—that the land is alienable and disposable—need only be satisfied at the time of the application’s filing. Here, the CENRO Certification confirmed the lands were within an alienable and disposable zone as of January 17, 1986, meeting this condition for the 1994 application.
However, the Court strictly applied the second requisite. For a successful registration under Section 14(1), the applicant must prove possession and occupation of the alienable land under a bona fide claim of ownership since June 12, 1945. The Court rejected the argument that possession prior to the land’s classification as alienable could be counted. Since the land was certified alienable only in 1986, any possession before that date could not be in the concept of an owner over a disposable asset. Therefore, respondents’ possession, even if traced back to 1955 for one lot, could not satisfy the “since June 12, 1945” requirement. Their possession, at best, commenced only after the 1986 classification, which was insufficient for original registration. The policy behind the law is to keep public domain lands inalienable until officially declared otherwise, and possession before such declaration does not confer a registrable right.