G.R. No. 163767, March 10, 2014
Republic of the Philippines, represented by The Director of Lands, Petitioner, vs. Rosario de Guzman Vda. de Joson, Respondent.

FACTS

Respondent Rosario de Guzman Vda. de Joson filed an application for land registration covering a 12,342-square meter riceland (Lot 2633, Cad-297) in Paombong, Bulacan. She claimed open, public, continuous, and adverse possession in the concept of an owner since 1926, tracing title from Mamerto Dionisio (original owner since 1907) to Romualda Jacinto (via 1926 deed of sale), then to Maria Jacinto (respondent’s mother) by inheritance, and finally to herself upon her mother’s death in 1963. She presented tax declarations and receipts. The Republic, through the Director of Lands and the Director of Forest Development, opposed, alleging the land was part of an unclassified region (forest land) under the Bureau of Forest Development’s jurisdiction and a portion of the Labangan Channel, thus inalienable. The Court of First Instance (CFI) granted the application, finding possession for over 30 years. The Court of Appeals affirmed, noting the Republic’s evidence (e.g., BF Map LC No. 637) was not formally offered and the respondent’s evidence stood unrebutted.

ISSUE

1. Whether the land subject of the application is susceptible of private acquisition.
2. Whether the trial court and the Court of Appeals erred in granting the application for registration.

RULING

The Supreme Court REVERSED the Court of Appeals and DISMISSED the application for registration.
1. On the susceptibility of private acquisition: The land was not proven to be alienable and disposable. For registration under Section 14(1) of Presidential Decree No. 1529, the applicant must prove: (a) the land is alienable and disposable public domain, and (b) open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier. The respondent failed to prove the first requisite. The Republic’s opposition, based on a 1927 BF Map classifying the area as an unclassified region (presumed forest land), shifted the burden to the respondent to prove the land’s alienability. She did not present a positive act of the government, such as a presidential proclamation or executive order, or an official classification map from the Department of Environment and Natural Resources (DENR), certifying the land as alienable and disposable. Mere tax declarations and payments are insufficient to overcome the presumption that land of the public domain is inalienable state property.
2. On the error in granting the application: The lower courts erred because possession, no matter how long, cannot ripen into ownership if the land remains part of the inalienable public domain. Under the Regalian doctrine, all lands not otherwise classified are presumed state property. Forest lands or unclassified lands cannot be acquired by prescription. The period of possession prior to the land’s reclassification as alienable is irrelevant, as prescription does not run against the State. Since the respondent did not establish that the land was alienable and disposable, her claim of possession since 1926 or 1945 was immaterial. The application was dismissed for failure to discharge the burden of proof under Section 14(1) of the Property Registration Decree.