GR 167652; (July, 2007) (Digest)
G.R. No. 167652 ; July 10, 2007
LIMCOMA MULTI-PURPOSE COOPERATIVE, Petitioner, vs. REPUBLIC OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Limcoma Multi-Purpose Cooperative filed an application for registration and confirmation of title over a 646-square-meter parcel of land in Rosario, Batangas. It claimed ownership through a 1991 deed of sale from the Spouses Venustiano and Arsenia Alcantara. The cooperative asserted that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession of the land in the concept of an owner since 1938, totaling over 30 years. To support its application, it presented testimonial evidence and a CENRO report stating the land was alienable and disposable and classified as commercial.
The Regional Trial Court granted the application. However, the Republic, through the Office of the Solicitor General, appealed. The Court of Appeals reversed the RTC, dismissing the application. The CA held that the petitioner failed to prove the land was part of the alienable and disposable lands of the public domain as of June 12, 1945, or that its predecessors-in-interest had possessed it since that date. The CA also found the testimonial evidence on possession insufficient. The petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the petitioner has sufficiently established its right to judicial confirmation of imperfect title under Section 48(b) of the Public Land Act, as amended.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court reiterated the stringent requirements for judicial confirmation of imperfect title. An applicant must prove: (1) the land forms part of the alienable and disposable agricultural land of the public domain; and (2) the applicant and his predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the same under a bona fide claim of ownership since June 12, 1945, or earlier.
The Court found the petitioner’s evidence deficient on both counts. First, the CENRO certification merely stated the land was “alienable and disposable” but crucially failed to establish that it had been classified as such on or before June 12, 1945. A certification must expressly state the date of such classification to satisfy the first requirement. Second, the testimonial evidence on possession was insufficient. The witnesses’ accounts were vague and general, lacking specific details about the nature and activities constituting possession since 1938. Mere casual cultivation or intermittent use does not equate to the required continuous occupation. Furthermore, the petitioner failed to establish the requisite possession in good faith and with just title for acquisitive prescription under the Civil Code. Consequently, the petitioner did not overcome the presumption that the land remains part of the inalienable public domain.