G.R. No. 171209 ; June 27, 2012
SPS. AMBROSIO DECALENG (substituted by his heirs) and JULIA “WANAY” DECALENG, et al., Petitioners, vs. BISHOP OF THE MISSIONARY DISTRICT OF THE PHILIPPINE ISLANDS OF PROTESTANT EPISCOPAL CHURCH IN THE UNITED STATES OF AMERICA, otherwise known as THE PHILIPPINE EPISCOPAL CHURCH, represented by RT. REV. ROBERT LEE O. LONGID, et al., Respondents.

FACTS

The Philippine Episcopal Church (PEC), through its Episcopal Diocese of Northern Philippines (EDNP), filed a complaint for Accion Reinvindicatoria and Accion Publiciana against Ambrosio Decaleng and others over two parcels of land in Sagada, Mountain Province. PEC-EDNP claimed ownership of the “Ken-geka” property by virtue of a Torrens title (Certificate of Title No. 15) originally issued in 1915 to its predecessor, The Domestic and Foreign Missionary Society of the Protestant Episcopal Church in the U.S., and later donated to PEC. It also claimed the “Ken-gedeng” property through open, continuous, and notorious possession since 1901. The defendants, members of the Igorot cultural community, asserted ownership based on their and their ancestors’ possession since time immemorial, arguing the lands were part of their ancestral domain.

ISSUE

The core issue is whether the petitioners, as members of a national cultural minority, have a superior claim to the subject lands based on native title or possession since time immemorial, which could prevail over the PEC’s registered title.

RULING

The Supreme Court ruled in favor of the PEC, upholding its registered title over the Ken-geka property. The Court emphasized the indefeasibility and conclusiveness of a Torrens title. Certificate of Title No. 15, issued in 1915, became incontrovertible after one year from its issuance. The petitioners’ claim of native title, while a recognized concept, cannot collaterally attack a title already perfected under the Torrens system. For the Ken-gedeng property, which was unregistered, the Court found that PEC-EDNP failed to conclusively prove its claim of possession since 1901. However, this did not automatically vest ownership in the petitioners. Their claim must be perfected through the appropriate judicial or administrative confirmation of imperfect title under the Public Land Act ( Commonwealth Act No. 141 , as amended). The Court clarified that possession since “time immemorial” must still be anchored on the legal requirements of open, continuous, exclusive, and notorious possession of alienable and disposable lands of the public domain since June 12, 1945, or for members of cultural minorities, under a bona fide claim of ownership. The petitioners’ remedy is to file a separate proceeding for confirmation of title, not to attack the PEC’s existing registered title. The decision of the Court of Appeals was affirmed with modification, dismissing the claim over Ken-gedeng without prejudice to the filing of the proper action.