GR 180086; (July, 2014) (Digest)
G.R. No. 180086 , July 2, 2014
AFP RETIREMENT AND SEPARATION BENEFITS SYSTEM (AFP-RSBS), Petitioner, vs. REPUBLIC OF THE PHILIPPINES, Respondent.
FACTS
On July 10, 1997, the Armed Forces of the Philippines Retirement and Separation Benefits System (AFP-RSBS) filed an application for original registration of three parcels of land in Silang, Cavite, with a total area of 48,151 square meters. AFP-RSBS acquired the properties from Narciso Ambrad, Alberto Tibayan, and Restituto Tibayan on March 13, 1997, and alleged that their predecessors-in-interest had been in possession since June 12, 1945. The Municipal Circuit Trial Court approved the application on July 28, 2001. The Republic of the Philippines appealed, arguing, among other grounds, that the properties were declared alienable and disposable only on March 15, 1982, and thus possession prior to that date should not be counted. The Court of Appeals reversed the trial court’s decision, dismissing the application on the grounds that the period of possession before the land was declared alienable and disposable could not be included in the computation, and that AFP-RSBS, as a private corporation, was prohibited from owning alienable lands of the public domain under the Constitution.
ISSUE
Whether the period of possession prior to the declaration that the land is alienable and disposable agricultural land should be included in the computation of the period of possession for purposes of original registration under Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree).
RULING
The Supreme Court ruled in favor of petitioner AFP-RSBS. The period of possession prior to the declaration that the land is alienable and disposable agricultural land is included in the computation of possession for purposes of acquiring registration rights, provided that the land has already been declared alienable and disposable at the time of the application for registration. The Court clarified that Section 14(1) of the Property Registration Decree requires only that the property be classified as alienable and disposable at the time the application is filed, not as of June 12, 1945. The Court followed its precedent in Republic v. Naguit, which held that excluding possession prior to the declaration of alienability would render the law inoperative and absurd, especially since the Philippines was not yet independent before June 12, 1945. The Court distinguished the contrary ruling in Republic v. Herbieto, stating that it had no precedential value regarding Section 14(1). Additionally, the Court held that AFP-RSBS, as a government corporation organized under Presidential Decree No. 361, as amended, is not covered by the constitutional prohibition against private corporations owning alienable lands of the public domain. The Court of Appeals’ decision was set aside, and the trial court’s decision approving the registration was reinstated.