GR 158449; (October, 2004) (Digest)
G.R. No. 158449; October 22, 2004
Luningning P. Del Rosario-Igtiben, Jose Reyes Igtiben, Jose Del Rosario Igtiben, Jr. and Theresa Topacio Medina, petitioners, vs. Republic of the Philippines and the Court of Appeals, respondents.
FACTS
Petitioners filed an application for judicial confirmation and registration of title over a 2,988-square-meter parcel of land in Silang, Cavite, under Presidential Decree No. 1529 (Property Registration Decree). They claimed acquisition by purchase and asserted that they and their predecessors-in-interest had been in actual, continuous, open, public, and adverse possession in the concept of owner for over 30 years. The Municipal Circuit Trial Court granted the application, tracing possession back to 1958 through tax declarations and a deed of absolute sale from the previous owners, the Tonido family.
The Republic, through the Office of the Solicitor General, appealed to the Court of Appeals, arguing petitioners failed to prove possession since June 12, 1945, as required by law. The Court of Appeals reversed the trial court and dismissed the application, holding that petitioners did not satisfy the requisite period of possession. Petitioners elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether petitioners have sufficiently established a registrable title to the subject land by proving open, continuous, exclusive, and notorious possession and occupation since June 12, 1945, or earlier.
RULING
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court clarified that the application, while filed under the Property Registration Decree, is essentially one for judicial confirmation of an imperfect title governed by Section 48(b) of Commonwealth Act No. 141, the Public Land Act, as amended. This provision explicitly requires that the applicant, by themselves or through predecessors-in-interest, must have been in open, continuous, exclusive, and notorious possession and occupation of alienable and disposable lands of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier.
The Court held that petitioners’ evidence, which only traced possession back to 1958, fell short of this mandatory statutory requirement. The tax declarations and the history of possession presented did not cover the critical period preceding June 12, 1945. The Court further distinguished the applicable law, noting that the thirty-year prescriptive period under Republic Act No. 6940 applies only to administrative applications for free patents, not to judicial confirmation of imperfect titles under Section 48(b) of the Public Land Act. Consequently, petitioners failed to overcome the presumption that the land remains part of the inalienable public domain.