G.R. No. 193305, January 27, 2021
Republic of the Philippines, Petitioner, vs. Banal na Pag-aaral, Phil., Inc., Respondent.

FACTS

Respondent Banal na Pag-aaral, Phil., Inc. filed an Amended Application for Registration of Lot Nos. 2304 and 2312, Cad. 482-D Amadeo Cadastre (consolidated as Lot No. 94047) situated in Barangay Dagatan, Amadeo, Cavite. It claimed ownership through continuous, exclusive, and notorious possession in the concept of an owner long before World War II, reckoned from its predecessors-in-interest, the Heirs of Hermogenes Bayot, who executed an Extrajudicial Partition of Estate with Deed of Absolute Sale dated September 4, 1997, conveying the lot to respondent. To prove the lot was alienable and disposable, respondent initially presented a CENRO Certification dated May 22, 2002, and a copy of an approved Consolidated Plan bearing a notation that the survey was done inside an alienable and disposable area. To prove possession since prior to June 12, 1945, respondent presented evidence that Hermogenes Bayot owned and possessed the lot since the early 1940s, held tax declarations, and was succeeded by his children who sold it to respondent. The RTC approved the application. The CA initially reversed the RTC, dismissing the case for failure to prove alienability. Upon respondent’s motion for reconsideration, it submitted a subsequent CENRO Certification dated December 9, 2008, and a certified copy of FAO No. 4-1656, which declared certain areas, including the location of the subject lot, as alienable and disposable as of March 15, 1982. The CA then issued an Amended Decision affirming the RTC’s approval. Petitioner Republic appealed, arguing respondent failed to prove possession since June 12, 1945, as the earliest tax declarations only dated back to 1948.

ISSUE

1. Whether respondent possessed the subject lot for the length of time required by law.
2. Whether respondent proved a registrable title thereto.

RULING

The petition is meritorious. The Supreme Court reversed the CA’s Amended Decision and Resolution.
1. On Alienability: Respondent sufficiently established that the subject lot is alienable and disposable land of the public domain. It presented the CENRO Certification and FAO No. 4-1656, which positively declared the area alienable and disposable as of March 15, 1982. These documents, found authentic, enjoy a presumption of regularity. The lot need not have been classified as alienable since June 12, 1945; it is sufficient that it was so classified at the time of the application’s filing, as held in Republic v. Naguit.
2. On Possession: Respondent failed to establish open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier. The earliest tax declaration presented was from 1948. While testimonial evidence stated possession since the early 1940s, such general statements, without specific acts of ownership, are insufficient. Tax declarations alone are not conclusive evidence of possession. Respondent did not present any document or concrete evidence of possession prior to 1948. Therefore, respondent did not meet the requisite period of possession mandated by Section 14(1) of Presidential Decree No. 1529.