G.R. No. 168065 /G.R. No. 168070, September 6, 2017
TRINIDAD DIAZ-ENRIQUEZ, ET AL. vs. DIRECTOR OF LANDS, ET AL. and GERONIMO SACLOLO, ET AL. vs. COURT OF APPEALS, ET AL.

FACTS

On December 27, 1974, Geronimo, Josefino, and Rodrigo Saclolo filed an application for registration of title over three parcels of land in Ternate, Cavite, with a total area of 375.2 hectares. They claimed acquisition through purchase and alleged that they and their predecessors-in-interest had been in actual, exclusive, and open possession since time immemorial. The Director of Lands opposed, arguing the lands were within the Calumpang Point Naval Reservation per Proclamation No. 307, were not alienable and disposable, and that judicial confirmation for lands over 144 hectares had lapsed under R.A. No. 6236 . Trinidad Diaz-Enriquez intervened, claiming the Saclolos had sold their rights to her in 1976. The Regional Trial Court (RTC) confirmed the Saclolos’ titles, finding the lands were private in character and thus excluded from the naval reservation, and later ordered the decree issued to Enriquez.
The Court of Appeals (CA) reversed the RTC. It found the lands were indeed within the naval reservation and that the applicants failed to prove the required open, continuous, exclusive, and notorious possession. The CA also held the RTC lacked jurisdiction because the survey plans were not properly verified as required by P.D. No. 239 and that the right to apply for confirmation of title for lands exceeding 144 hectares had expired. The Saclolos and Enriquez filed separate petitions for review.

ISSUE

The core issue is whether the Saclolos and their successor-in-interest, Enriquez, have sufficiently established their right to judicial confirmation of imperfect title over the subject lands.

RULING

The Supreme Court denied the petitions and affirmed the CA decision. The legal logic rests on the fundamental requirements for judicial confirmation of imperfect title under the Public Land Act. First, the applicant must prove that the land is alienable and disposable public land. The Court found the applicants failed to discharge this burden. The certification from the Department of Environment and Natural Resources (DENR) presented was dated 1993, which only proved the land’s classification nearly two decades after the application was filed in 1974. Crucially, there was no proof that the land was already classified as alienable and disposable on June 12, 1945, or at the time the applicants’ alleged possession commenced.
Second, the Court agreed with the CA that the applicants failed to prove the requisite possession and occupation. The informacion possessoria they heavily relied upon did not specify the area claimed, and their other evidence, like tax declarations and deeds of sale, did not convincingly demonstrate open, continuous, exclusive, and notorious possession for the required period. Third, the Court upheld the CA’s finding on jurisdictional grounds. The survey plans covering the lands lacked the mandatory verification and approval by the Lands Management Bureau, a fatal defect that deprived the trial court of jurisdiction to hear the application. Consequently, without proof of alienability and disposability as of the required date, insufficient evidence of possession, and a jurisdictional flaw, the application for registration was properly dismissed.