G.R. No. 166890 , June 28, 2016
Republic of the Philippines, Petitioner, vs. Apolonio Bautista, Jr., Respondent.

FACTS

Respondent Apolonio Bautista, Jr. applied for judicial confirmation of imperfect title over Lot 17078 in Subic, Zambales. He claimed ownership through succession from his father, Apolonio Bautista, Sr., who allegedly purchased the lot from Mario Jardin and Cornelia Villanueva in 1971 and 1973. The father had the property declared for taxation and possessed it until his death in 1987. Apolonio Jr. and his siblings executed an extra-judicial settlement, with the siblings waiving their rights in his favor. He then filed the application in 1996, presenting deeds of sale, tax declarations, and his own testimony that his father possessed the land since 1969. The Municipal Trial Court granted the application, a decision affirmed by the Court of Appeals, noting the government’s failure to timely object to the evidence presented.
The Republic appealed, arguing that the applicant’s testimony regarding his father’s possession was hearsay and lacked probative value. More critically, the government contended that the application failed to meet the mandatory requirement of proving possession since June 12, 1945, or earlier, as required by law for judicial confirmation of imperfect title over alienable public lands.

ISSUE

Whether respondent Apolonio Bautista, Jr. sufficiently established his and his predecessors-in-interest’s open, continuous, exclusive, and notorious possession of the subject alienable land since June 12, 1945, or earlier, to warrant judicial confirmation of imperfect title.

RULING

The Supreme Court reversed the lower courts and dismissed the application. The legal logic is anchored on the stringent requirements for judicial confirmation of imperfect title under Section 48(b) of Commonwealth Act No. 141 (Public Land Act), as amended by Presidential Decree No. 1073, and Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree). These laws expressly limit the right to apply for confirmation to citizens who, by themselves or through predecessors-in-interest, 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 the applicant’s evidence utterly failed to trace possession back to this critical date. The earliest possession claimed, even if fully credited, only began in 1969 through the father. No evidence whatsoever connected possession to June 12, 1945. The amendment by P.D. No. 1073 changed the requisite period from thirty years preceding the application to possession since June 12, 1945, making this a substantive condition that cannot be waived. The government’s failure to object to the hearsay testimony was immaterial, as the core deficiency was the applicant’s failure to prove a statutory requirement essential to convert public land into private property. Without proof of possession since the mandated date, no imperfect title could be confirmed, regardless of the admissibility of other evidence. The application was therefore fatally defective.