GR 191516; (June, 2014) (Digest)
G.R. No. 191516, June 4, 2014
Republic of the Philippines, Petitioner, vs. Francisca, Geronimo and Crispin, all surnamed Santos, Respondents.
FACTS
Respondents Francisca, Geronimo, and Crispin Santos filed an Application for Registration of title for four parcels of land (Lot Nos. 536, 1101, 1214, 1215) in Taguig. They later moved to drop Lot No. 536 from the application. The Regional Trial Court (RTC) granted the application for registration. The Republic, through the Solicitor General, appealed to the Court of Appeals (CA), which affirmed the RTC’s decision. The Republic filed a Petition for Review on Certiorari before the Supreme Court. The respondents presented, among other documents, a Certification from the Department of Environment and Natural Resources (DENR) dated March 9, 2006, stating the subject lots were “verified to be within Alienable and Disposable Land, under Project No. 27-B of Taguig as per Land Classification Map No. 2623, approved on January 3, 1968.”
ISSUE
Whether the trial court and the CA were correct in finding that respondents had sufficient evidence showing that (1) the subject lots had been declared alienable and disposable lands of the public domain at the time the application was filed; and (2) that respondents had been in open, continuous, exclusive, and notorious possession of the land for the time required by the law when they filed their application for registration.
RULING
The Supreme Court GRANTED the petition, SET ASIDE the CA Decision, and DENIED the application for registration. The Court held that the respondents failed to present sufficient evidence to overcome the presumption that the land forms part of the public domain. Specifically, they did not prove the lots were classified as alienable and disposable. The required evidence are: (1) a CENRO or PENRO Certification; and (2) a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records. The mere DENR certification presented by the respondents was insufficient. The Court emphasized that an applicant must establish the existence of a positive act of the government, such as a presidential proclamation, executive order, administrative action, investigation reports, or a legislative act. In view of this failure, the Court did not find it necessary to discuss the second issue regarding possession.