GR 163766; (June, 2006) (Digest)
G.R. No. 163766 June 22, 2006
Republic of the Philippines, Petitioner, vs. Candy Maker, Inc., represented by its President, Ong Yee See, Respondent.
FACTS
Candy Maker, Inc. filed an application for original registration of title over two parcels of land, Lots 3138-A and 3138-B, in Taytay, Rizal, under Presidential Decree No. 1529. The company claimed ownership through purchase from the Cruz family, whose predecessors-in-interest allegedly possessed the land since time immemorial. The Municipal Trial Court (MTC) granted the application, a decision affirmed by the Court of Appeals. The Republic, through the Office of the Solicitor General and the Laguna Lake Development Authority (LLDA), opposed the registration, asserting that the land, particularly Lot 3138-A, forms part of the Laguna Lake bed. The LLDA presented a memorandum from its engineer indicating the lot is located below the reglementary lake elevation of 12.50 meters, classifying it as public land under Republic Act No. 4850 .
ISSUE
Whether the respondent has sufficiently established that the subject land is alienable and disposable public land and that it has acquired a registrable title thereto.
RULING
The Supreme Court granted the petition and reversed the lower courts’ decisions. The Court held that the applicant failed to prove the land is alienable and disposable. For land registration, the applicant must conclusively establish that the land is part of the alienable and disposable public domain. The burden of proof lies with the applicant, and the State need not present evidence to prove its public character. The LLDA’s evidence, showing the lot is below the reglementary lake elevation, prima facie established it as part of the lake bed, a property of public dominion under Article 502 of the Civil Code. The applicant’s evidence, primarily tax declarations and testimonial possession, was insufficient to overcome this presumption. The Court emphasized that possession, no matter how long, cannot ripen into ownership over inalienable public land. Furthermore, the applicant failed to present a certification from the proper government agency that the land was classified as alienable and disposable. Consequently, the application for registration must be denied.