G.R. No. 190817 , January 10, 2018
Republic of the Philippines, Petitioner vs. Rovency Realty and Development Corporation, Respondent

FACTS

Respondent Rovency Realty and Development Corporation (RRDC) filed an application for original registration of title over a 318,345-square-meter parcel of land in Cagayan de Oro City. RRDC claimed ownership through a 1997 deed of sale from P.N. Roa Enterprises, Inc., and asserted that it and its predecessors-in-interest had been in open, continuous, adverse, and peaceful possession of the land since time immemorial. The Republic of the Philippines opposed the application, arguing that RRDC failed to prove possession since June 12, 1945, and that the land, exceeding twelve hectares, was inalienable public domain.
The Regional Trial Court granted RRDC’s application, a decision affirmed by the Court of Appeals. The CA held that RRDC successfully traced its title to a 1937 deed of sale and proved the required possession. The Republic elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the grant of RRDC’s application for original registration of title.

RULING

Yes. The Supreme Court reversed the lower courts’ decisions and denied the application. The legal logic is anchored on the stringent requirements for judicial confirmation of imperfect title under Section 14(1) of the Property Registration Decree. An applicant must prove: (a) that the land is alienable and disposable public land, and (b) that the applicant and predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier.
The Court found RRDC’s evidence of possession fatally deficient. The earliest document presented was a 1937 deed of sale, but there was no competent evidence, such as a certification from the Department of Environment and Natural Resources, to establish that the land was already classified as alienable and disposable on that date or, crucially, by June 12, 1945. Possession prior to the land’s classification as alienable and disposable cannot be counted toward the required period. Furthermore, the Court noted inconsistencies and gaps in the chain of title and a lack of conclusive proof of the required possession and occupation for the entire period. Consequently, RRDC failed to discharge its burden of proving that the land had been converted to private property through acquisitive prescription, rendering its application without merit.