G.R. No. 177947 November 27, 2008
SPS. GABRIEL LLANES and MARIA LLANES, petitioners, vs. REPUBLIC OF THE PHILIPPINES, respondent.

FACTS

Petitioners Spouses Gabriel and Maria Llanes applied for registration of title over a parcel of land in Malvar, Batangas. The property had been possessed by Gabriel’s grandmother, Eugenia Valencia, since the 1930s, cultivated as agricultural land, and subsequently purchased by Gabriel’s brother, Servillano Llanes, in 1965. The spouses purchased the land from Servillano in 1995. They later sold it to ICTSI Warehousing, Inc. in 1996. ICTSI initially filed an application for registration in 1997, but due to a technicality regarding the tax declaration, the application was amended to substitute the Spouses Llanes as the applicants. The Municipal Circuit Trial Court (MCTC) granted their application. The Republic appealed, arguing the spouses failed to prove the land was alienable and disposable and that they and their predecessors-in-interest had possessed it since June 12, 1945. The Court of Appeals reversed the MCTC, relying on a CENRO Certification stating the land became alienable only on December 22, 1997 (after the application was filed), and finding the evidence of possession insufficient. The spouses moved for reconsideration, attaching a corrected CENRO Certification stating the land was alienable since March 26, 1928, but the Court of Appeals denied the motion.

ISSUE

Whether the Court of Appeals erred in reversing the MCTC’s grant of the application for registration based on its finding that the subject property became alienable and disposable only on December 22, 1997.

RULING

Yes, the Court of Appeals erred. The Supreme Court found merit in the petition. The corrected CENRO Certification, which was submitted to the Court of Appeals, conclusively established that the land was classified as alienable and disposable since March 26, 1928, satisfying the first requisite under Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree) that the property must be alienable and disposable at the time of the application. The Court held that the appellate court should have considered this certification. Furthermore, the evidence on record—including tax declarations and testimonies of open, continuous, exclusive, and notorious possession and cultivation by the spouses and their predecessors-in-interest since the 1930s—sufficiently established possession under a bona fide claim of ownership since June 12, 1945, or earlier. Therefore, the Spouses Llanes complied with all requisites for registration, and the Court of Appeals’ decision was reversed and set aside.