G.R. No. 160990 ; September 11, 2006
Republic of the Philippines, petitioner, vs. Spouses Ricardo B. Enriquez and Eliza M. Enriquez, respondents.

FACTS

Respondents filed an application for original registration of title over two parcels of land in Daet, Camarines Norte: Lot 1711 (455 sqm) and a second parcel described in plan Psu-05-006497-D (297 sqm). The Republic, through the Director of Lands, opposed, alleging the land was part of the public domain and that respondents failed to prove the requisite possession since June 12, 1945. The Regional Trial Court granted the application, a decision affirmed by the Court of Appeals.
The Republic elevated the case via a petition for review, arguing the trial court lacked jurisdiction due to respondents’ failure to present the original tracing cloth plan and that respondents did not prove open, continuous, exclusive, and notorious possession for the required period.

ISSUE

Whether the Court of Appeals erred in affirming the grant of the application for land registration.

RULING

The petition is partially granted. The Supreme Court modified the lower courts’ decisions, denying registration for the 297-square meter parcel but affirming it for Lot 1711. On jurisdiction, the Court clarified that while the submission of the original tracing cloth plan or a sepia copy is mandatory for land identification, substantial compliance is permissible. For Lot 1711, respondents submitted a blueprint copy certified by the Land Management Services and a certification that the lot was not part of a prior public land grant, which sufficed for identification.
However, for the 297-square meter parcel, a fatal material discrepancy existed. The technical description in the application and the surveyor’s certification indicated different lot numbers (Psu-05-006497-D vs. Psu-05-006497), creating uncertainty in the land’s identity. This discrepancy, which the CA failed to properly consider, warranted a denial of registration for that specific parcel for failure to establish its precise identity.
On the issue of possession, the Court found that respondents and their predecessor-in-interest had possessed Lot 1711 openly, continuously, exclusively, and notoriously since 1963, supported by tax declarations and receipts. While this period fell short of the required possession since June 12, 1945, for original registration under Section 14(1) of P.D. No. 1529, the Court applied the alternative period provided under Section 14(2)—possession for at least thirty years. The 34-year possession, coupled with the filing of the application in 1997, satisfied this requirement. The application itself constituted a conclusive declaration of ownership against the State. Therefore, registration of Lot 1711 was correctly granted.