GR 193358; (September, 2020) (Digest)
G.R. No. 193358 & G.R. No. 193399, September 16, 2020
Republic of the Philippines, Petitioner, vs. Heirs of the Late Leopoldo de Grano, et al., Respondents / Violeta Sevilla, Petitioner, vs. Heirs of the Late Leopoldo de Grano, et al., Respondents
FACTS
The Heirs of the Late Leopoldo de Grano filed an amended application for original registration of title over Lot 7467, Cad. 355-D, Tagaytay Cadastre, under Presidential Decree No. 1529. They claimed their family had been in possession and ownership for over 30 years, supported by Tax Declaration No. 019-0163 and tenant testimonies. The Republic of the Philippines opposed, arguing the lot was part of the public domain, not proven alienable and disposable, and the Heirs failed to prove possession since June 12, 1945. Oppositor Violeta Sevilla also opposed, asserting the DENR had primary jurisdiction as it had entertained her Miscellaneous Sales Application (MSA) over the property, which led to DENR Orders and an Office of the President (OP) Resolution denying the Heirs’ claim over a portion. The Regional Trial Court initially granted the Heirs’ application but, upon Sevilla’s motion for reconsideration, reversed itself, denying the application based on the binding effect of the OP Resolution and the Heirs’ failure to prove possession since 1945 and alienable status. The Court of Appeals initially dismissed the Heirs’ appeal but, on reconsideration, amended its decision and ordered the registration of an 8.4120-hectare portion of the lot in favor of the Heirs, finding the OP Resolution affected only 5 hectares and that a DENR certification and a 1958 CFI decision established alienability and possession. The Republic and Sevilla filed separate petitions for review.
ISSUE
The primary issues were whether the Heirs complied with the substantive and procedural requirements for original registration of title under Section 14(1) of P.D. No. 1529, specifically: (1) proving the land is alienable and disposable public land, and (2) proving open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier.
RULING
The Supreme Court granted the petitions and reversed the Amended Decision of the Court of Appeals. The application for registration was denied.
The Court held that the Heirs failed to prove the land was alienable and disposable at the time of their application in 1991. The DENR certification they presented referred to the land’s status in 1997, six years after filing, which did not satisfy the requirement that the classification must exist at the time of application. The Court also ruled that the Heirs failed to prove possession since June 12, 1945. Their earliest tax declaration was from 1948, and they did not provide sufficient evidence to bridge the gap from 1945. The 1958 CFI decision they referenced pertained to a different 50-hectare property, not the specific Lot 7467. Furthermore, the tax declarations they presented covered only 3 hectares and differed in location and boundaries from Lot 7467, failing to establish possession over the entire area applied for. The principle of res judicata did not bar the application concerning the portion not covered by Sevilla’s MSA, but the Heirs’ failure to meet the substantive requirements for registration was fatal to their claim.