G.R. No. 175177; October 24, 2012
Republic of the Philippines, Petitioner, vs. Gloria Jaralve, et al., Respondents.

FACTS

Respondents filed an application for original registration of a 731,380-square-meter parcel of land in Cebu City. They claimed ownership through purchase from predecessors-in-interest who allegedly possessed the land openly, continuously, exclusively, and notoriously since June 12, 1945, or earlier. In support, they submitted various documents, including a CENRO certification dated March 20, 1996, stating the land was within the alienable and disposable zone of the public domain. The Republic of the Philippines, through the Director of Lands, opposed the application, arguing the respondents failed to prove the requisite possession and that the land remained part of the inalienable public domain.
The Regional Trial Court granted the application for registration, and the Court of Appeals affirmed the decision. The appellate court held that the CENRO certification was sufficient to prove the land’s alienable and disposable character. The Republic elevated the case to the Supreme Court via a petition for review on certiorari, contending that the evidence presented was inadequate to overcome the presumption that the land belongs to the public domain.

ISSUE

Whether the respondents have successfully proven that the subject land is alienable and disposable and that they have acquired a registrable title through open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier.

RULING

The Supreme Court granted the petition and reversed the lower courts’ decisions. The Court held that the respondents failed to discharge the burden of proof required for original registration. For land registration under Section 14(1) of Presidential Decree No. 1529, applicants must conclusively establish two fundamental facts: first, that the land forms part of the alienable and disposable agricultural land of the public domain; and second, that they and their predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier.
The legal logic is strict. The CENRO certification presented by the respondents, while a necessary document, was insufficient by itself. The Court, citing Republic v. T.A.N. Properties, Inc., ruled that such a certification must be accompanied by a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records. This requirement ensures the land was officially declared alienable and disposable on or before the required possession commenced. The respondents’ certification, lacking this supporting executive declaration, did not constitute conclusive evidence. Consequently, they failed to overcome the presumption that the land remains part of the inalienable public domain. Without first establishing this indispensable prerequisite, any discussion on the quality and duration of possession becomes moot. The application for registration was therefore properly dismissible.