G.R. No. 175760 February 17, 2016
Republic of the Philippines, Petitioner, vs. Sogod Development Corporation, Respondent.

FACTS

Respondent Sogod Development Corporation filed an application for original registration of title over a parcel of land in Sogod, Cebu, claiming ownership through purchase from Catalina Rivera in 1996. It averred that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945, or earlier. The Republic, through the Office of the Solicitor General, opposed the application primarily on two grounds. First, it argued that the land was classified as forest land and was certified as alienable and disposable only on January 17, 1986, making possession prior to that date inconsequential. Second, it contended that a private corporation is disqualified from applying for original registration under the 1987 Constitution .
The Municipal Circuit Trial Court granted the application, a decision affirmed by the Court of Appeals. The appellate court held that the respondent had sufficiently proven possession by itself and its predecessors since a time preceding June 12, 1945. It further ruled that once the required possession is proven, the land is converted into private property, and the subsequent judicial confirmation is a mere formality, thereby allowing the corporation to be the applicant.

ISSUE

Whether the Court of Appeals erred in affirming the grant of the application for original registration of title in favor of Sogod Development Corporation.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court clarified the applicable legal principles for judicial confirmation of imperfect title under Section 48(b) of the Public Land Act. It held that for a successful application, the applicant must prove: (a) that the land is alienable and disposable, and (b) that the applicant and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the same under a bona fide claim of ownership since June 12, 1945, or earlier. Crucially, the Court explained that the land need only be classified as alienable and disposable at the time of the application for registration, not from June 12, 1945. The requirement of possession since that date is separate and distinct. Therefore, the fact that the land was declared alienable only in 1986 does not disqualify the application, provided the requisite possession since 1945 is proven. On the second issue, the Court reiterated that when a corporation applies for registration over land already converted to private property through prescribed possession, it is not applying for a grant of public land but for confirmation of a title that already exists. The constitutional prohibition against corporations acquiring alienable public lands does not apply to lands already rendered private by operation of law. The Court found the respondent’s evidence, including testimonies and tax declarations, sufficient to establish the required possession.