G.R. No. 179905; August 19, 2009
Republic of the Philippines, Petitioner, vs. Neptuna G. Javier, Respondent.

FACTS

Respondent Neptuna Javier filed an application for original registration of title over a 12,903.50-square-meter parcel of land in Taytay, Rizal. She claimed open, continuous, exclusive, and notorious possession since June 12, 1945, through herself and her predecessor-in-interest, Catalina Javier. The Republic of the Philippines, through the Office of the Solicitor General, and the Laguna Lake Development Authority (LLDA) filed oppositions. The LLDA specifically contended that based on its topographic map, the lot was below the reglementary lake elevation of 12.50 meters and thus formed part of the bed of Laguna Lake, constituting public land.
The Municipal Trial Court (MTC) granted Javier’s application and ordered registration. The Court of Appeals affirmed the MTC decision. The Republic elevated the case via certiorari, arguing Javier failed to prove the land was alienable and disposable and that her possession met the required period. The Republic also challenged the sufficiency of the LLDA’s opposition, as it was filed by its General Manager without proof of authority, and argued the LLDA’s evidence on the land’s classification was inadmissible for not being formally offered.

ISSUE

The core issue is whether Javier successfully established that the subject land is alienable and disposable agricultural land of the public domain and that she and her predecessor-in-interest possessed it in the manner and for the period required by law for judicial confirmation of imperfect title.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court held that Javier satisfactorily proved the requisite possession. Tax declarations in the name of her predecessor from 1950 and in her own name from 1966, coupled with her testimony and that of a witness regarding continuous cultivation, constituted clear and convincing evidence of open, continuous, exclusive, and notorious possession since 1945. The Court emphasized that tax declarations are good indicia of possession.
Regarding the land’s alienable status, the Court ruled that the LLDA’s opposition, while filed by its General Manager, was valid. A signature by a high-ranking official like the General Manager carries the presumption of regularity in the performance of official duties. More critically, the Court found that the Republic itself failed to rebut the presumption that the land is alienable. In land registration cases, the burden shifts to the State to prove that the land remains part of the inalienable public domain after the applicant has shown possession. The Republic presented no certification from the proper government agency attesting that the land was not classified as alienable and disposable. The LLDA’s topographic map, which was not formally offered in evidence, could not be considered. Consequently, Javier’s possession, coupled with the State’s failure to prove the land’s inalienability, warranted confirmation of her title.