G.R. No. 179181; November 18, 2013
ROMAN CATHOLIC ARCHBISHOP OF MANILA, Petitioner, vs. CRESENCIA STA. TERESA RAMOS, assisted by her husband PONCIANO FRANCISCO, Respondent.

FACTS

The Roman Catholic Archbishop of Manila (RCAM) filed an application for original registration of title over two parcels of land in Taguig under the Public Land Act. RCAM claimed ownership since the Spanish era and open, continuous possession. The Republic of the Philippines opposed, asserting the lands were part of the public domain. Respondent Cresencia Sta. Teresa Ramos also opposed, claiming she and her predecessors-in-interest had possessed the property since Spanish times, presenting various documentary and photographic evidence of family businesses and activities conducted on the land.
The Regional Trial Court denied RCAM’s application, finding it failed to prove actual possession. The court noted RCAM’s only overt act was constructing a structure in 1991, and its tax declarations were insufficient to prove possession. In contrast, the RTC found Ramos’s evidence demonstrated her family’s actual possession. However, the RTC refused to issue title to Ramos, citing her failure to include a specific prayer for issuance in her opposition. The Court of Appeals affirmed the denial of RCAM’s application but modified the ruling by confirming Ramos’s imperfect title, subject to compliance with registration requisites.

ISSUE

Whether the Court of Appeals erred in confirming respondent Ramos’s imperfect title to the subject properties.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle is that for a judicial confirmation of imperfect title, the applicant must prove: (1) the land forms part of the alienable and disposable land of the public domain, and (2) open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. The Court found that RCAM failed to meet this burden. Its evidence of possession was weak, primarily consisting of recent tax declarations and a single act of construction in 1991, which did not establish the required possession since 1945.
Conversely, Ramos presented conclusive evidence of possession. The totality of her evidence, including photographs of family businesses on the land, certificates for various enterprises, and testimonial evidence even from RCAM’s own witnesses, clearly established that she and her predecessors had possessed the property openly and continuously in the concept of owners since the Spanish period, satisfying the requisite period. The Court held that her failure to declare the property for tax purposes or to include a specific prayer for title in her opposition did not defeat her vested right, which had already accrued through possession. The right to registration arises from possession, and the formal application is merely a procedural confirmation of that pre-existing right. Thus, the CA correctly recognized her imperfect title.