G.R. No. 192393, March 27, 2019
FIL-ESTATE MANAGEMENT, INC., MEGATOP REALTY DEVELOPMENT, INC., PEAKSUN ENTERPRISES AND EXPORT CORPORATION, ARTURO E. DY AND ELENA DY JAO, PETITIONERS, VS. REPUBLIC OF THE PHILIPPINES AND SPOUSES SANTIAGO T. GO AND NORMA C. GO, REPRESENTED BY THEIR SON AND ATTORNEY-IN-FACT KENDRICK C. GO, RESPONDENTS.

FACTS

Spouses Santiago and Norma Go filed an application for original registration of title over three parcels of land in Las Piñas City. They presented deeds of sale from 1964 and 1967, and tax declarations, to prove ownership and possession. The Republic of the Philippines, through the Office of the Solicitor General, and the Fil-Estate Consortium, opposed the application. The Fil-Estate Consortium claimed that portions of the lots applied for overlapped with properties already registered under their Torrens titles, presenting their own titles and a deed of sale. The Regional Trial Court (RTC) granted the Go spouses’ application.
The Court of Appeals (CA) reversed the RTC’s decision and dismissed the application for registration. The CA ruled that the Go spouses failed to prove two indispensable requisites: first, that the lands were alienable and disposable public land, and second, that they and their predecessors-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the lands since June 12, 1945, or earlier. The CA noted that the earliest tax payment presented was only from 1991, which was insufficient to prove the required possession. The Fil-Estate Consortium filed a Petition for Partial Review on Certiorari before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in dismissing the application for registration of title filed by the Go spouses.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the Go spouses failed to discharge the burden of proof required in land registration cases. For original registration under the Public Land Act and Property Registration Decree, applicants must conclusively prove that the land is alienable and disposable public land and that they 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 evidence presented, primarily tax declarations with payments commencing only in 1991, was inadequate to establish possession dating back to the required period. The Court emphasized that it is not a trier of facts and found no compelling reason to deviate from the CA’s factual findings, which are generally binding and conclusive. The petitioners also failed to demonstrate that the case fell under any recognized exception to this rule or that the CA committed a reversible error of law. Consequently, the application for registration was properly dismissed for failure to meet the stringent evidentiary standards for judicial confirmation of imperfect title.