G.R. No. 171726 ; February 23, 2011
VICENTE YU CHANG AND SOLEDAD YU CHANG, Petitioners, vs. REPUBLIC OF THE PHILIPPINES, Respondent.

FACTS

Petitioners Vicente and Soledad Yu Chang filed an application for registration of title over two parcels of land in Pili, Camarines Sur. They claimed ownership through inheritance from their father, L. Yu Chang, who acquired the property via an exchange agreement with the Municipality of Pili in 1949. The family subsequently possessed the land, built improvements, and paid real property taxes. After their father’s death, the petitioners acquired the shares of their siblings through a Deed of Transfer and Renunciation. The Regional Trial Court granted their application for registration.
The Republic, through the Office of the Solicitor General, opposed the application, arguing the applicants failed to prove the land was alienable and disposable and that they possessed it since June 12, 1945. On appeal, the Court of Appeals reversed the RTC. The CA found that the petitioners failed to present incontrovertible evidence that the subject lands were classified as alienable and disposable. It relied on the testimony of a CENRO officer who stated the area was classified as forest land prior to October 30, 1986.

ISSUE

Whether the petitioners have sufficiently proven that the subject parcels of land are alienable and disposable lands of the public domain, thus entitling them to judicial confirmation of imperfect title.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision dismissing the application for registration. The legal logic is anchored on the fundamental principle that for a judicial confirmation of an imperfect title under Section 48(b) of the Public Land Act, the applicant must prove two critical elements: (1) that the land is alienable and disposable public land, and (2) that the applicant and his predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the same since June 12, 1945, or earlier.
The Court emphasized that the burden of proof rests squarely on the applicant. In this case, the petitioners failed to discharge the first and most fundamental requisite. The certification from the CENRO officer categorically stated the land was classified as forest land, and thus not alienable and disposable, prior to October 30, 1986. The Court held that a positive act of the government, such as a presidential proclamation or a Department of Environment and Natural Resources (DENR) Secretary’s classification, is required to reclassify forest land into alienable or disposable land. The mere existence of tax declarations and receipts, or the fact that the area is now used for residential or commercial purposes, does not constitute sufficient evidence of such reclassification. Without proof that the land was already classified as alienable and disposable on or before June 12, 1945, the period of possession—no matter how long—is legally inconsequential. The land remains part of the inalienable public domain. Consequently, the petitioners could not acquire ownership by prescription, and their application was properly dismissed.