GR 173088; (June, 2008) (Digest)
G.R. No. 173088 ; June 25, 2008
Republic of the Philippines, petitioner, vs. Imperial Credit Corporation, respondent.
FACTS
Respondent Imperial Credit Corporation applied for original land registration over a parcel of land in Antipolo City. It claimed ownership through a 1966 deed of sale from Jose Tajon, alleging it was subrogated to Tajon’s possession, which was open, continuous, exclusive, and notorious since June 12, 1945. The Regional Trial Court granted the application, finding the land alienable and respondent’s evidence sufficient. The Court of Appeals affirmed, holding respondent qualified under Section 14(2) and (4) of Presidential Decree No. 1529.
The Republic, through the Office of the Solicitor General, appealed, contending the application was actually based on Section 14(1) of P.D. No. 1529 for judicial confirmation of imperfect title. It argued respondent failed to present incontrovertible evidence that its predecessor-in-interest possessed the land since June 12, 1945, as required by law.
ISSUE
Whether the Court of Appeals erred in affirming the grant of respondent’s application for original land registration.
RULING
Yes, the petition is meritorious. The Supreme Court reversed the Court of Appeals. The core legal principle is that under the Regalian doctrine, all lands of the public domain belong to the State, and any applicant for confirmation of imperfect title bears the burden of proving open, continuous, exclusive, and notorious possession and occupation since June 12, 1945, or earlier. The Court found respondent’s evidence insufficient to meet this stringent requirement.
Respondent’s claim was properly anchored on Section 14(1) of P.D. No. 1529, not the other paragraphs cited by the appellate court. While respondent proved the land was alienable and disposable, its evidence of possession was flawed. The earliest tax declaration presented was only from 1993, which is inadequate to substantiate possession since 1945. Testimonies regarding possession were general and failed to establish the specific nature, continuity, and exclusivity of possession required from the critical date. Mere assertions of possession, without corroborative and conclusive evidence like specific acts of ownership dating back to 1945, cannot overcome the presumption that the land remains part of the inalienable public domain. Consequently, respondent failed to discharge its burden of proof.