G.R. No. 163254 ; June 1, 2007
Republic of the Philippines, Petitioner, vs. Albina Sta. Ana-Burgos, Respondent.

FACTS

Respondent Albina Sta. Ana-Burgos filed an application for original registration of title over an 850-square-meter parcel of land in Taytay, Rizal. She claimed ownership through a 1979 deed of donation from her father, Mateo Sta. Ana, who allegedly inherited it from his parents. She asserted that she and her predecessors-in-interest had been in open, continuous, exclusive, and notorious possession of the land in the concept of an owner for more than fifty years, even prior to June 12, 1945. To support her application, she presented the deed of donation, tax declarations, a survey plan, and a DENR certification stating the land was alienable and disposable. She also testified and presented witnesses to corroborate her possession.
The Republic of the Philippines, through the Office of the Solicitor General, opposed the application. It argued that respondent and her predecessors failed to prove possession since June 12, 1945, that her documentary evidence was of recent vintage, and that the land remained part of the inalienable public domain. The Regional Trial Court granted the application, a decision affirmed by the Court of Appeals. The Republic elevated the case to the Supreme Court via a petition for review.

ISSUE

Whether respondent Albina Sta. Ana-Burgos has sufficiently established a registrable title to the subject property under the Public Land Act ( Commonwealth Act No. 141 ) and the Property Registration Decree (Presidential Decree No. 1529).

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic centered on the requirements for judicial confirmation of imperfect title. For such an application to succeed, an applicant must prove: (1) that the land forms part of the alienable and disposable agricultural land of the public domain, and (2) that they, by themselves or through their 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.
The Court found both requisites were met. First, the DENR certification presented by respondent constituted conclusive proof that the land was classified as alienable and disposable. Second, the combination of respondent’s testimony, corroborating witness accounts, and tax declarations spanning several decades constituted competent evidence to establish the required character and duration of possession. The Court emphasized that while tax declarations are not conclusive evidence of ownership, they are good indicia of possession in the concept of an owner, especially when coupled with actual possession. The Republic’s mere opposition, unsupported by contrary evidence, could not overcome this factual finding. The trial court’s assessment of the witnesses’ credibility, affirmed by the Court of Appeals, is binding on the Supreme Court.